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.
Administrative Setup for QSEHRA Reimbursement
To enable reimbursements for premiums under a spouse’s employer-sponsored group plan, employers need to:
Log in to the Admin Portal of the QSEHRA tool.
Update settings to allow spouse group plan reimbursements.
Save the changes for immediate application within the system. This ensures that all eligible claims can be processed efficiently under the QSEHRA policy.
PREMIUMS
If you’re covered by your spouse’s group plan there are some nuances to know regarding premium reimbursement:
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).
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. All documents must reflect the premium amount and tax status (pre-tax or post-tax).
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.
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.