QSEHRA & Marketplace APTC help

Nov 21, 2018

  1. MKIndy

    MKIndy New Member

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    This is a shot in the dark in hopes that a broker or assister on here has enrolled clients on the Marketplace who were offered premium reimbursement via a QSEHRA and who were also APTC eligible. How did you do it?

    I get the gist of it: Employers can reimburse some of their employees' health insurance premiums pre-tax via a QSEHRA and those employees can even get a premium tax credit (advance or otherwise) on the Marketplace so long as they:

    1. Determine if small business HRA monthly allowance qualifies as affordable coverage.
    2. Adjust the amount of the tax credit to reflect QSEHRA monthly allowance.
    I get that the applicant who is applying for an APTC is supposed to inform the Marketplace regarding the QSEHRA reimbursement, but I'm unsure how they are supposed to do that via the Marketplace application process. I can easily reduce the amount of the tax credit to reflect the QSEHRA offset, but how are you supposed to determine if the the HRA monthly allowance qualifies as affordable coverage via the app? Is this something I'm supposed to work out ahead of time or is there some way to include it on the app. If I were to just work it out ahead of time, then are we still getting the safe harbor protection for the insured at tax time that you get when the marketplace determines that an employer plan is not affordable?

    a few sources: What happens to premium tax credits with a QSEHRA?

    & https://www.irs.gov/pub/irs-drop/n-17-67.pdf
    MKIndy, Nov 21, 2018