Skip to main content

ICHRA Employer: Understanding the Tax Treatment of ICHRA Reimbursements

This article is for employers administering an Individual Coverage Health Reimbursement Arrangement (ICHRA) through Take Command who want to understand the tax treatment of reimbursements.

D
Written by David Hung

Eligible ICHRA reimbursements are generally tax-free for both employers and employees when reimbursement requirements are met.

Are ICHRA reimbursements taxable?

Generally, no. Reimbursements for eligible health insurance premiums and qualified medical expenses are typically excluded from employees' taxable income when ICHRA requirements are satisfied.


Are employers required to pay payroll taxes on reimbursements?

Eligible ICHRA reimbursements are generally not treated as taxable wages for payroll tax purposes.

Employers should continue to follow applicable payroll and tax reporting requirements.


What expenses qualify for tax-free reimbursement?

Tax-free reimbursement generally applies to:

  • Eligible individual health insurance premiums

  • Qualified medical expenses allowed under the employer's HRA plan

Only approved expenses may be reimbursed.


What happens if an employee submits an ineligible expense?

Ineligible expenses should not be approved for reimbursement.

If an incorrect reimbursement is issued, employers may need to correct the payment according to their payroll and accounting procedures.


What documentation is required?

Employees must submit documentation demonstrating that the expense qualifies under the employer's ICHRA and applicable IRS requirements.

Incomplete documentation may delay or prevent reimbursement approval.


When does this article not apply?

This article provides general information about ICHRA reimbursement taxation.

It does not replace tax, accounting, or legal advice for an employer's specific situation.


Key takeaway

Eligible ICHRA reimbursements are generally tax-free when employees maintain eligible coverage, submit required documentation, and receive reimbursement for approved expenses under the employer's HRA plan.

Did this answer your question?