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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
QSE-HRA: Small Employer HRA Plan Documents Just $199
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PDF Brochure –Core QSE-HRA Qualified Small Employer HRA Plan Document (with forms)
