With respect to newly eligible employees, QSEHRA reimbursements may be made as soon as the employee becomes eligible, assuming the employee has satisfied all additional requirements (for example, substantiation) for receiving the reimbursement.
Unlike certain other types of accounts, QSEHRAs are permitted to reimburse employees for over-the-counter drugs purchased without a prescription without jeopardizing qualification, but these reimbursements are taxable because IRC Section 106(f) only permits them to be excluded if a prescription is obtained.