Who is included?
To remain compliant, the QSEHRA must be made available in a fair manner to your employees. You do have to offer it to all of your full-time employees. From there, you can choose to structure your QSEHRA offering in a few ways:
(1) Offer your QSEHRA to ALL employees
(regardless of how many hours they work per week, or months they work per year, etc.)
(2) Exclude one or more groups of employees:
Employees who have not completed up to 90 days of service with the company
Employees who have not attained age 25 before the beginning of the plan year
Employees who work less than a certain number of hours per week (threshold set by the employer)
Employees who work less than a certain number of months per year (threshold set by the employer if there are seasonal employees)
How do I structure reimbursement allowances?
You have the option to vary rates based on family status (single, couple, or family) or by age. Just remember that everyone in a given family status receives the same rate. If you do include part-time and seasonal workers, for example, they must receive the same rate as full-time employees in the same age group or family status. As long as everyone that fits the criteria you set is treated fairly, you're good to go.
There is no minimum contribution a company can make, but the annual contributions for 2021 are maxed at $5,300 for a single employee and $10,700 for an employee with a family.
NOTE: Remember that an employee must have insurance coverage that qualifies as Minimum Essential Coverage (MEC) in order to be eligible for reimbursement through QSEHRA. Most group plans and full coverage individual health plans purchased through the marketplace (healthcare.gov or takecommmandhealth.com) qualify. The most common exceptions we see are short-term plans and coverage for only vision and dental plans. Also, see our blog post about Christian Sharing Ministries, another type of plan we see often.