Yes, those covered on a spouse's employer group plan can participate in the QSEHRA. Remember: You must be covered by Minimum Essential Coverage (MEC) to receive QSEHRA reimbursements. Coverage through a spouse's group plan does qualify as MEC. Additionally, if dependents are included under the health plan, QSEHRA reimbursement tier eligibility will be determined by the individuals actively listed in the plan submitted for reimbursement, not the total household composition. For example, if dependents transition to a separate plan, the QSEHRA tier may adjust lower (e.g., from family to individual).
Administrative Setup for QSEHRA Reimbursement
PREMIUMS
If you’re covered by your spouse’s group plan there are some nuances to know regarding premium reimbursement:
Employees covered under their spouse's group health plan will generally fall into the Self-Only QSEHRA tier unless the spouse is listed as a dependent on the submitted insurance plan.
First, verify whether your employer has elected to include spouse group plans in the QSEHRA.
Next, only the portion of the group premium that is not paid for by your spouse’s company is eligible for reimbursement. For example, let’s say your spouse’s plan costs $1,000/mo total. Your spouse’s company kicks in $400/mo to help cover the cost. Only the remaining $600 would be eligible for QSEHRA reimbursement (if allowed by the employer, see step 1 above).
Finally, most group plans are already paid for on a pre-tax basis on your spouse’s paycheck. In the example above, even though you’re paying $600/mo to cover the difference, your spouse is likely able to pay for it pre-tax on his or her paycheck. This is great! However, the IRS doesn’t want you to “double dip” and also get a pre-tax QSEHRA reimbursement. As a result, your QSEHRA claim for your premium will likely be paid on a taxable basis unless you can show the premiums were paid post-tax by your spouse (very rare). To comply with QSEHRA rules, ensure that no single expense is reimbursed using multiple accounts simultaneously, to avoid duplicate claims.
Keep in mind that QSEHRA tier changes can occur if participants (e.g., dependents or spouses) shift to separate health coverage. Such changes may adjust reimbursement amounts based on the new tier.
Additionally, when submitting a claim for premium reimbursement, ensure to include necessary documentation as proof of eligibility. Examples of documentation include benefits election forms from the spouse’s employer, recent pay stubs showing premium deductions, and confirmations of active coverage. For different coverage scenarios, documentation must clearly specify the name of the insured, plan details, premium payments, and relevant dates. It should also indicate whether coverage qualifies for individual, couple, or family QSEHRA reimbursement tiers.
See IRS Notice 2017-67 Q48 if you’d like to dive into the weeds!
Required Documentation for QSEHRA Claims
For claims related to premiums or medical expenses, employees must submit proper documentation. Examples include online insurance screenshots, letters from HR indicating coverage, or pay stubs displaying premium deductions. All documentation must highlight active coverage and the amount being paid, whether taxed pre- or post-tax. Additionally, ensure that the documentation specifies the claimant and verifies that the expense aligns with QSEHRA reimbursement rules to avoid compliance issues.
Updates to documentation should also reflect changes in coverage status, specifying whether the new insurance qualifies as individual, couple, or family coverage to ensure compliance.
If you have an individual dental or vision plan, separate from your spouse's group health plan, those premiums can be reimbursed tax-free.
If you would like to know more about showing proof of coverage on a spouse group plan check it out here!
EXPENSES
If your employer has elected to reimburse for both premiums and medical expenses, your claims for one-time medical expenses can be reimbursed tax-free.
For recurring medical expenses like prescriptions or therapy sessions, ensure to upload proof of payments to streamline future reimbursements and avoid redundancy in claims. All claims must align with the QSEHRA policy and be supported by receipts or corresponding invoices.