QSEHRAS vs. ICHRAS

February 27, 2020

HOW DO QUALIFIED SMALL EMPLOYER HRAS (QSEHRA) COMPARE TO INDIVIDUAL COVERAGE HRAS (ICHRA)

 

QSEHRA

ICHRA

Size
 

Employers with 50 or less employees
 

Any size employer
 

Group Health Plans (GHP)
 

Cannot also offer GHP
 

Can offer GHP to separate class
 

Class
 

All non-excludable
 

Offered on same terms within class
 

Eligibility
 

Individual coverage, GHP through spouse, alternative healthcare are allowed
 

Must be enrolled in individual coverage or Medicare, no GHP
 

Maximum
 

$5,150/$10,450 per year (different each year)
 

None
 

Expenses
 

Eligible medical expenses*, individual health premiums, including spouse coverage through their employer
 

Eligible medical expenses*, individual health premiums, Medicare (+supplements), catastrophic health
 

Approval
 

Medical substantiation required; initial proof of MEC required annually before first expense approved and self-attestation at claim filing
 

Medical substantiation required, self-attestation of MEC annually and at claim filing
 

Premium Tax Credit (PTC)
 

Any PTC recieved is reduced by the amount of the QSEHRA allowance
 

Employees are ineligible for the PTC when enrolled in a ICHRA
 

Carryover
 

Allowed; reimbursements can't exceed max
 

Allowed
 

Health Savings Account (HSA)
 

Not HSA Compatible
 

Can be designed to be HSA Compatible
 

Medicare Secondary Payer (MSP)
 

 Not subject to CMS Reporting
 

Subject to standard CMS Reporting rules
 

COBRA
 

Not COBRA-eligible
 

COBRA-eligible if covered by individual health coverage
 

*§213(d)

QSEHRA

QSEHRAs are open to employers with fewer than 50 full-time employees that do not offer group health insurance. When employees sign up for a Qualified Small Employer HRA, the employer is the one making contributions to the QSEHRA. That means no money will be deducted from the employee’s paychecks.

ICHRA

ICHRAs can be integrated with, and reimburse premiums for, individual health insurance coverage chosen by employee if certain conditions are met. ICHRAs can be offered by an employer of any size and has no cap on the amount of contribution like a QSEHRA does.  

Still have questions? Give us a call at 800-264-9462.

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