Policies and Procedures for 2026 Reimbursement Adjustments and Employer Contributions
Overview
Adjustments to reimbursement amounts and policies are crucial as employers and employees navigate changes in the QSEHRA and ICHRA frameworks for 2026. In this guide, we outline key policies, timing guidelines, and processes for updating contributions and managing reimbursements efficiently.
Adjusting Reimbursement Amounts in 2026
Employers are allowed to adjust reimbursement amounts starting in January 2026. However, it is advisable to confirm any planned adjustments in advance to ensure a smooth transition .
QSEHRA Reimbursement Rates
For QSEHRA-specific updates, the 2026 reimbursement rates have not yet been announced. The IRS typically releases annual maximum reimbursement amounts later in the year. Until these new rates are published, existing 2025 settings will carry over if renewals are not completed. Employers and employees will be notified once the updated rates are available .
Estimating ICHRA Contributions for 2026
To account for potential increases in ACA premiums, consider the following:
Limited Plan Access: If employees have access to one or few plans, employers should budget an ICHRA allowance of approximately $625 per month to offset a 25% premium increase and maintain purchasing power.
Wide Plan Access: If employees have various plan options (on and off the exchange), a smaller allowance increase (5–10%) may suffice. Employees may identify lower-cost plans, maintaining comparable purchasing power .
These projections are valuable for modeling contributions and planning effective adjustments for 2026.
Timing and Documentation for Reimbursements
Out-of-Platform Plan Selections (November and December 2025)
Employees can claim reimbursements for months preceding the effective start of 2026 platform-based plan selections. For example, reimbursements can be processed for November and December 2025, provided:
Employees purchase their health plan through the Marketplace (or similar channels) outside the platform.
Proof of coverage is submitted, demonstrating eligibility under the plan. Once this documentation is uploaded, reimbursements for 2025 can be approved .
Reimbursement Rate Change Timelines
Rate changes for reimbursements are often restricted to specific periods, such as before the start of a new plan year or during renewals. If attempting to adjust rates mid-plan year, further assistance may be required from Take Command support .
Key Takeaways
Employers can update reimbursement allowances starting January 2026 and should plan adjustments to align with IRS policy updates.
IRS announcements about QSEHRA rates are expected late in the year; timely updates ensure smooth renewals.
Anticipate ACA premium increases and strategize ICHRA contribution adjustments accordingly.
Document-based reimbursements remain a valid option for preceding months (e.g., late 2025), with clear proof requirements.
Rate changes are restricted outside of yearly renewals but can be facilitated with support if necessary.
For further assistance or plan-specific concerns, contact Take Command support.