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.
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.”
– 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
*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.
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
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
QSE-HRA: Small Employer HRA Plan Documents Just $199
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