8818 / When should QSEHRA reimbursements be made?

QSEHRAs are permitted to make reimbursements available ratably, on a month-by-month basis, rather than making the full amount of the QSEHRA benefit available at the beginning of the year.

Example: Employer provides a QSEHRA with an annual permitted benefit of $3,000 and provides that $250 of that benefit will be available as each month of the year elapses. Employee submits substantiation for $4,000 in qualified medical expenses in January. The QSEHRA may provide that the employee will receive $250 in reimbursements for the claim each month.

QSEHRAs are not permitted to impose deductible or other cost-sharing requirements before reimbursements become available. QSEHRAs also may not reimburse employees for expenses incurred before the employer provides the employee with the QSEHRA (for this purpose, medical expenses are considered incurred when the care is received, not when the medical bill is paid). However, premium expenses may be treated as though they were incurred (a) on the first day of each month of coverage, on a pro-rata basis, (b) on the first day of the period of coverage or (c) on the date the premium is paid.