ICHRA vs. QSEHRA: How do they compare?
Compare two popular HRAs to help you pick the right one for your organization.
Are you wondering if a QSEHRA or ICHRA is best for your employees? Book a call with a personalized benefits advisor to get answers to your questions.
Not sure which HRA is best for your organization?
If you’re a business owner wanting to offer a health benefit for the first time or searching for an alternative to traditional group health insurance, a health reimbursement arrangement (HRA) is an easy to manage employee benefit.
The QSEHRA is uniquely suited for small employers, while the ICHRA can be offered by employers of all sizes. Both allow organizations to give money to their employees to purchase individual health coverage and other out-of-pocket medical expenses.
While both HRAs operate in similar ways, they vary in how they can be customized, who they can be offered to, and more.
This page outlines similarities and differences between the two health benefits so you can determine which is the best choice for your employees.
What is an ICHRA?
An ICHRA is an employer-funded health benefit used to reimburse an organization’s employees for their individual health insurance premiums and other qualifying medical expenses tax-free.
Rather than being covered by an employer-chosen group health insurance policy, employees will covered by an ICHRA can choose and purchase their own individual coverage policy.
Employers of any size can offer an ICHRA to their employees either as a stand-alone health benefit or to specific employee classes that don’t qualify for your group health insurance plan.
ICHRAs are particularly beneficial for applicable large employers (ALEs) looking to satisfy the Affordable Care Act’s employer mandate but don’t want to pay for costly group health insurance or be subject to annual premium rate increases.
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What is a QSEHRA?
Like the ICHRA, a QSEHRA allows eligible employers to reimburse employees, tax-free, for their health insurance coverage and a wide range of healthcare expenses. However, in order to offer a QSEHRA, an employer must have fewer than 50 full-time equivalent employees (FTEs).
The benefit can’t be offered with a group insurance health plan or a flexible spending account (FSA). Unlike an ICHRA, employees don't need a qualifying form of individual health insurance in order to participate. However, in order for reimbursements to be tax-free, they'll need minimum essential coverage (MEC).
The IRS sets annual maximum contribution limits for QSEHRAs, so the amount an employer can give is capped. If the employer allows yearly rollover capabilities, the rollover amount is restricted so they don’t exceed the following year’s annual limit.
All in all, QSEHRAs are an excellent way for small employers to provide healthcare benefits to attract and retain talent without breaking the bank.
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How are the ICHRA and QSEHRA the same?
QSEHRAs and ICHRAs are most notably the same in their reimbursement method. Employers set an allowance amount, employees make a qualified purchase, and they are reimbursed when the expense is reviewed and approved. But there are other ways these two employee benefits interact that are similar in structure.
Both QSEHRAs and ICHRAs are employer-owned and employer-funded health benefits. But they’re not pre-funded accounts. This is good for employers because HRA funds are only paid out to the employee when they incur a qualified expense ready for reimbursement.
Additionally, unlike the FSA or health savings account (HSA), all HRA contributions made by the employer belong to the company. This means that when an employee leaves the organization, they don’t take any HRA funds with them.
With ICHRA and QSEHRA coverage, employees are allowed to get reimbursed for qualified medical expenses dictated by IRS Publication 502. There are over 200 eligible expenses ranging from health insurance premiums, prescription drugs, doctor visits, and more.
Some expenses are only reimbursable with a doctor’s note explaining why the medication or treatment is necessary. Still, several other over-the-counter items are reimbursable with a receipt indicating the purchase was made.
HRAs have substantial tax advantages for both employers and employees alike. All employer HRA contributions are tax-deductible and payroll tax-free. Employees don’t have to pay income taxes on the reimbursements they receive either, as long as their individual health insurance policy meets MEC.
What are the differences between an ICHRA and a QSEHRA?
It’s clear that ICHRAs and QSEHRAs have a good amount in common. But they do have pretty significant differences in their structure and flexibility that we’ll go over in the sections below.
With the ICHRA, employers can set different allowance amounts based on 11 specific employee classes. These classes categorize employees into groups for better health benefit customization.
The classes must be determined by legitimate job-based criteria, like salaried or hourly, part-time or full-time employees. Additionally, all employees in the same class must receive the same allowance amount.
While an ICHRA allows for varying allowance amounts based on many employee classes, QSEHRAs only allow employers to vary reimbursement amounts based on age and family size. However, if you're offering a QSEHRA with PeopleKeep, only varied allowance amounts by family status are permitted. All full-time W-2 employees must be offered QSEHRA coverage.
ICHRAs offer quite a bit of flexibility in terms of employer contribution. They have no minimum or maximum contribution limits, so employers can choose an allowance amount that best fits their budget and their employees’ needs.
However, QSEHRAs have maximum contribution limits for single and family statuses determined by the IRS each year. However, there’s no minimum contribution limit for the QSEHRA.
Premium tax credits
Employees offered an ICHRA who also qualify for a premium tax credit can pick if they want to participate in the ICHRA or collect their tax credit. However, this decision depends on if their ICHRA is deemed affordable.
If an employee has an affordable ICHRA allowance, they will be unable to receive their tax credits even if they don’t participate in the ICHRA coverage. If an allowance is considered unaffordable, employees can opt-in or out of the ICHRA based on who’s offering the larger amount.
With a QSEHRA, employees can keep their premium tax credit and participate in the QSEHRA. But employees have to reduce their tax credit offering by the amount of their QSEHRA allowance, and they don’t have the option to opt-in or out.
QSEHRA vs. ICHRA comparison chart
The chart below compares key differences between the two HRAs and highlights which option is best for certain company goals.
|Employer eligibility requirements||Available to businesses of any size with or without group health insurance, as long as the group health plan and ICHRA aren’t offered to the same employee classes.||Available to businesses with fewer than 50 full-time equivalent employees who don’t offer group health insurance.|
|ACA employer mandate||May satisfy the employer mandate for ALEs if coverage is affordable and offered to more than 95% of full-time employees.||Not available for ALEs with over 50 FTE employees. Only ALEs are subject to the employer mandate.|
|Employee eligibility||The business can structure eligibility guidelines based on predefined employee classes, such as full-time, part-time, salaried, hourly, and seasonal. Employees must have qualified individual health insurance to participate.||All full-time employees are automatically eligible. Businesses can choose to extend eligibility to part-time employees but must offer the same allowances to both groups. Employees aren’t required to have individual health insurance.|
|Annual allowance caps||None.||The following annual caps exist for 2023:
|Rollover guidelines||Month-to-month permitted, but no annual rollover.||Month-to-month is permitted, but monthly allowances are capped to prevent total contributions from exceeding the annual maximum.|
|Budgetary guidelines||Businesses can offer different allowance amounts to employees based on class as well as employee age and family status.||Businesses can offer different allowance amounts to employees based on family status.|
|Premium tax credit guidelines||Employees can’t have both the premium tax credit and the ICHRA. They may waive premium tax credits and participate in the ICHRA, or opt-out of the ICHRA and collect premium tax credits if the HRA allowance amount is considered unaffordable.||Employees with premium tax credits can participate in the QSEHRA, but their premium tax credit will be reduced by the amount of their QSEHRA allowance. Employees cannot opt-out of the QSEHRA.|
|Best suited for||Organizations that:
Get a downloadable version of the HRA comparison chart
How can you choose between an ICHRA and a QSEHRA?
The best way to choose between an ICHRA and a QSEHRA for your organization is to consider your company’s needs. If you’re looking for a more flexible health benefit, such as greater customization with employee classes, unlimited annual contribution limits, or satisfying the employer mandate, an ICHRA is likely your best option.
However, if your goal is a health benefit that’s more cost-effective than group health insurance, easily implemented and administered, and works for qualified small employers with less than 50 employees, a QSEHRA is the right way to go.
Whichever HRA you choose, you’ll be selecting a customizable health benefit that will empower your employees to take more control over their own healthcare decisions while saving your company money.
And with PeopleKeep, we’ll help you administer your QSEHRA or ICHRA so you can rest assured knowing that documentation review and compliance regulations are being handled for you.
See whether an ICHRA or a QSEHRA is right for your business
Frequently asked questions
What expenses are eligible with an ICHRA and QSEHRA?
HRAs can reimburse many healthcare products and services, including insurance premiums, provided they are not already paid with pre-tax dollars. Use our IRS expense tool to see which expenses can be eligible for reimbursement.
What is the difference between an HRA and an HSA?
An HRA is an arrangement between an employer and an employee allowing employees to get reimbursed for their medical expenses, while an HSA is a portable account that the employee owns and keeps with them even after they leave the organization. With an HRA, the employee only gets paid when they incur an eligible expense, while an HSA is pre-funded each month regardless of whether or not they spend the money.
Can an ICHRA and QSEHRA satisfy the employer mandate?
Only eligible employers can implement a QSEHRA, which means they must have had fewer than 50 full-time employees or FTEs in the prior calendar year. Under the ACA, regulations only apply to employers with 50 or more employees, so the QSEHRA wouldn’t be subject to the employer mandate.
On the other hand, an ICHRA can satisfy the employer mandate as long as the allowances offered to employees are considered affordable. Learn more about how affordability and other rules apply in our article: ICHRA and the employer mandate.
Can business owners participate in an ICHRA or QSEHRA?
Some business owners can participate in an HRA depending on how they file.
C-corporation owners: C-corporations are legal entities separate from the owner. This means owners are considered common-law employees of the corporation and are eligible to participate in this benefit. As with all employees, this eligibility extends to the C-corp owner’s family as well. All reimbursements paid to the C-corp owner and the owner’s family are tax-free to the company and the owner.
Sole proprietors: A sole proprietorship is an unincorporated business owned and run by one person. There’s no distinction between the business and the owner, so the owner isn't an employee. This means sole proprietors can’t participate.
But, if the owner is married to a W-2 employee of the business, the owner could gain access through their spouse’s allowance as a dependent. All reimbursements would be tax-free to both the sole proprietorship and the owner’s spouse.
Partners: A partnership is a pass-through entity, which means the company isn't subject to income tax. Instead, the partners are directly taxed individually. Partners in a partnership are considered self-employed, rather than employees of the company, so they’re not eligible to participate in a reimbursement benefit.
Similar to sole proprietors, partners can access the benefit if they are married to a W-2 employee of the business, as long as the partner’s spouse isn’t also a business partner.
S-corporation owners: An S-corporation is a pass-through entity, meaning the company isn’t subject to income tax. Instead, shareholders (i.e., owners who own 2 percent or more of the company’s shares) are directly taxed individually. This means shareholders aren’t considered employees and aren’t eligible to participate in a reimbursement benefit.
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