No, employers do not need to fund a separate account for QSEHRA or ICHRA because both are reimbursement arrangements, meaning employees are reimbursed only after submitting eligible expenses rather than drawing from a pre-funded account.
Do you need a separate account for QSEHRA or ICHRA?
No separate or pre-funded account is required
QSEHRA and ICHRA are not savings accounts, debit accounts, or HSA/FSA-style funds.
Instead, they are:
Reimbursement arrangements
Employer-funded benefits paid after claims are approved
Administrative systems that track eligible expenses
Employers only pay when an employee submits a valid, approved reimbursement request.
How reimbursement funding actually works
Employers pay only after approval of eligible expenses
The process works like this:
Employee pays for a qualified health expense (premium or medical service)
Employee submits documentation (receipt, invoice, or proof of coverage)
Claim is reviewed for eligibility and compliance
Employer reimburses the employee after approval
There is no advance deposit required into a dedicated account.