One of the questions we receive most from employers and employees is how QSEHRA (small business HRA) affects premium tax credits for plans purchased through the marketplace. This post walks through the ins and outs of premium tax credits (PTCs) and QSEHRAs.
A friendly reminder: Please note that we are not licensed tax professionals. Our mission is to empower small business owners and entrepreneurs to make smart decisions when it comes to health insurance.
What happens to premium tax credits with QSEHRA?
For QSEHRA, the answer depends on whether or not the reimbursement offer from the employer is considered affordable. If it is affordable, the employee is not allowed to accept the premium tax credits. If it is NOT considered affordable, then the employee is allowed to accept the tax credits, but must reduce them dollar for dollar by the amount the employer offered (we will show the math below).
Calculating Premium Tax Credits
Premium tax credits are based on income and insurance affordability. The IRS has set guidelines for determining eligibility for the premium tax credit and the size of the tax credit.
1. Determine if small business HRA monthly allowance qualifies as affordable coverage:
- The employee must determine if the premium for self-only coverage through the second-lowest-cost silver plan offered on their local exchange minus the QSEHRA monthly allowance is less than 9.83% of their household income for the month.
- For example, if the monthly allowance is $300 per month and the exchange premium is $500, then if $500 - $300 = $200 is less than or equal to 9.83% of the employee's monthly income, the allowance makes this coverage affordable and the employee doesn't qualify for a premium tax credit that month.
2. If the offer from the employer is NOT considered affordable, then the employee can accept a portion of the tax credits and the reimbursement:
- For example, if the employee is eligible for a $400 premium tax credit and receives $300 allowance from their small business QSEHRA, they would be able to use only $100 of the tax credit.
- The employee should request the adjusted tax credit from the exchange when purchasing their insurance policy.
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Steps employees must take
It is very important that employees purchasing a plan through the marketplace and receiving a premium tax credit notify their insurance provider immediately about their small business HRA benefit. The insurance provider will recalculate the employee tax credit with the small business HRA benefit. Failure to report the small business HRA to your insurer will result in having to pay back the tax credits to the IRS during tax time.
Filing Taxes
Beginning with the 2017 tax year, employees will need to report the QSEHRA benefit on their taxes on IRS Form 8962. The benefit is reported on all employee W-2’s regardless if they have received any reimbursement during the year; Therefore, we do not recommend employees opt-out of QSEHRA in attempt to keep the PTC.
Have questions on premium tax credits and QSEHRA?
Want to learn more about your small business HRA plan? Our Employee Guide is a great place to get started. If you have a question we have not answered, please feel free to contact us!
Again, we are not licensed tax professionals so please consult with one before making any decisions for your company.
Another great resource you might find helpful is the reimbursement rules chapter in our handy new QSEHRA Guide!
