Can a Medicare eligible employee participate in an HRA? 

YES! Medicare eligible employees can participate in an Individual Coverage Health Reimbursement Arrangement (ICHRA) or Qualified Small Employer Health Reimbursement Arrangement (QSEHRA).

What does a Medicare eligible employee need to participate in an HRA?

For ICHRA an employee must have Part A and Part B (or Part C) to qualify for participation in an HRA. Part B by itself does not qualify as Minimum Essential Coverage.

For QSEHRA an employee must have Minimum Essential Coverage (MEC). Part A or Part C will qualify as MEC.

Can an employer reimburse premiums and expenses for Medicare eligible employees?

An ICHRA may be used to reimburse premiums for Medicare and Medicare supplemental health insurance (Medigap) as well as eligible medical expenses. Parts A, B, C, D and Medigap are all eligible.

QSEHRA can be used to reimburse premiums for Medicare and Medicare supplemental health insurance (Medigap) as well as eligible expenses.

More ICHRA + Medicare Considerations

When transitioning from traditional group plan to an ICHRA, employees will need to ensure they have both Medicare Part A and Part B. Employees that are Medicare eligible will likely have Part A. Losing their group plan will qualify them to register for Part B as a Special Enrollment Period (SEP).