Health plans that qualify as MEC for QSE-HRA plans

Employers providing a Qualifying Small Employer Health Reimbursement Arrangement (QSE-HRA) are required to obtain proof of Minimum Essential Coverage (MEC) before issuing reimbursement of a claim for eligible medical expenses. The following information will be helpful for both the employer and employee in determining the health plans that qualify as MEC for QSE-HRA eligibility.

List of health plans that qualify as MEC for QSE-HRA participation

Click here to download the Types of Minimum Essential Coverage (QSE-HRA) document, which lists the types of health plans that qualify as MEC.

From IRS Notice 2017-67, Qualified Small Employer Health Reimbursement Arrangements, Part III — Administrative, Procedural, and Miscellaneous, p. 57, Appendix A:

“Minimum essential coverage means health care coverage under any of the following programs. It does not, however, include coverage consisting solely of excepted benefits. Excepted benefits include stand-alone vision and dental plans, workers’ compensation coverage, and coverage limited to a specified disease or illness.”

Types of Minimum Essential Coverage (QSE-HRA)

Employer-sponsored coverage:

•  Group health insurance coverage for employees under:

– A plan or coverage offered in the small or large group market within a state,

– A plan provided by a governmental employer, such as the Federal Employees Health Benefit program, or

– A grandfathered health plan offered in a group

• A self-insured health plan for employees,
• COBRA coverage,
• Retiree coverage, or
• Coverage under an expatriate health plan for employees and related

Individual health coverage:

• Health insurance purchased directly from an insurance company,
• Health insurance purchased through the Marketplace,
• Health insurance provided through a student health plan,
• Catastrophic coverage, or
• Coverage under an expatriate health plan for non-employees such as students and

Coverage under government-sponsored programs:

• Medicare Part A coverage,
• Medicare Advantage plans,
• Most Medicaid coverage,*
• Children’s Health Insurance Program (CHIP) coverage,
• Most types of TRICARE coverage,
• Comprehensive health care programs offered by the Department of Veterans Affairs,
• Health coverage provided to Peace Corps volunteers,
• Department of Defense Nonappropriated Fund Health Benefits Program,
• Refugee Medical Assistance, or
• Coverage through a Basic Health Program (BHP) standard health plan.

Other coverage:

• Certain foreign coverage,
• Certain coverage for business owners, or
• Coverage recognized by HHS as minimum essential **

*Medicaid programs that provide limited benefits generally don’t qualify as minimum essential coverage.

**Plans recognized as minimum essential coverage are listed at: www.cms.gov/CCIIO/Programs-and- Initiatives/Health-Insurance-Market-Reforms/minimum-essential-coverage.html, scroll down and click on the link for the list of approved plans.

Attestation forms

In addition to the handout, Types of Minimum Essential Coverage (QSE-HRA) document, which lists the types of health plans that qualify as MEC, Core Documents provides these forms for employee attestation to proof of MEC for QSE-HRA eligibility:

Employee Attestation for Initial Proof of MEC

Attestation for Reimbursement of an Incurred Expense

Related articles:

QSE-HRA reimbursement to employees without health insurance

What qualifies as proof of MEC for QSE-HRA eligibility?

How to Report QSE-HRA Employee Benefits on 2017 Form W-2

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