If you’re a small-business owner and you’d like to reimburse your employees, pre-tax, for the cost of health insurance that they buy on their own, you have two options: An ICHRA (Individual Coverage Health Reimbursement Arrangement) or a QSEHRA (Qualified Small Employer Health Reimbursement Arrangement).1
As long as you have fewer than 50 full-time equivalent (FTE) employees and don’t also offer a group health plan, you have your choice of either an ICHRA or a QSEHRA. Note that only employers with fewer than 50 FTE employees can select a QSHERA.
Read our overviews of ICHRAs and QSEHRAs.
What are the differences between a QSEHRA and an ICHRA?
Here’s a summary of how these two types of health reimbursement arrangements compare, to help you determine which one will be a better fit for your business:
Key differences between ICHRA and QSEHRA |
||
|---|---|---|
| ICHRA | QSEHRA | |
| Eligible employer size | Available to employers of any size.2 | The employer must have fewer than 50 full-time equivalent employees.3 |
| Can the employer also offer a group health plan? | Yes, as long as the ICHRA and group plans are offered to different employee classes.4 | No.3 |
| Are there caps on how much an employer can reimburse? | No, this is up to the employer.4 | Yes. In 2025, reimbursements are capped at $6,350 for a single employee, or $12,800 for an employee with family coverage.5 (Employers can set lower limits.) |
| Can employees use the benefit in addition to a Marketplace subsidy? | No.4 Learn more about Marketplace plan affordability and ICHRAs. | Yes, but the subsidy amount is reduced by the amount of the QSEHRA.6 |
| Do employees get an individual-market special enrollment period when the reimbursement arrangement becomes available to them? | Yes. | Yes. |
| What type of coverage can employees have? | Individual-market coverage or Medicare.4 | Any minimum essential coverage.7 (If it’s a group plan through their spouse’s employer, pre-tax QSEHRA reimbursement is likely not available, because group premiums are typically already paid with pre-tax dollars.)8 |
| Can out-of-pocket medical expenses be reimbursed? | Yes, if allowed by the employer.4 | Yes, if allowed by the employer.3 |
| Are there minimum contribution or participation requirements? | No.9 | No.10 |
| Can different benefits be offered to different employees? | Yes, if you divide your employees into aauthorized classes and offer different benefits to different classes. (If any classes are being offered a traditional group plan instead of an ICHRA, each class must have at least 10 employees.)4 | No, the QSEHRA must be offered on the same terms to all eligible employees. (Employees might receive different reimbursement amounts, depending on the receipts they submit for reimbursement.)10 |
Footnotes
- “Health Reimbursement Arrangements (HRAs): 3 things to know” HealthCare.gov. Accessed May 20, 2025 ⤶
- “Health Reimbursement Arrangements (HRAs)” and “FAQs on New Health Coverage Options for Employers and Employees” Internal Revenue Service. June 13, 2019. Accessed May 20, 2025 ⤶
- “Notice 2017-67, Qualified Small Employer Health Reimbursement Arrangements” Internal Revenue Service. Accessed May 20, 2025 ⤶ ⤶ ⤶
- “FAQs on New Health Coverage Options for Employers and Employees” Internal Revenue Service. June 13, 2019. Accessed May 20, 2025 ⤶ ⤶ ⤶ ⤶ ⤶ ⤶
- "Revenue Procedure 2024-40" Internal Revenue Service. Accessed May 20, 2025 ⤶
- “Notice 2017-67, Qualified Small Employer Health Reimbursement Arrangements” Internal Revenue Service. And “Qualified Small Employer HRAs (QSEHRAs)” HealthCare.gov. Accessed May 20, 2025 ⤶
- “Notice 2017-67, Qualified Small Employer Health Reimbursement Arrangements” (Appendix A) Internal Revenue Service. Accessed May 20, 2025 ⤶
- “Cures Act – QSEHRA Q&A” Washington Healthplanfinder. Accessed May 20, 2025 ⤶
- “Guide to the individual coverage HRA (ICHRA)” PeopleKeep. Accessed May 20, 2025 ⤶
- “2025 Guide for Qualified Small Employer HRAs (QSEHRA)” Take Command. Accessed May 20, 2025 ⤶ ⤶