The ICHRA Broker

Guide

HRA eligible expenses: what you can be reimbursed for

An HRA can reimburse a wide range of medical costs tax-free — and, depending on the type, health insurance premiums too. This guide breaks down HRA eligible expenses in detail: what''s covered, what''s not, how it differs by HRA type, and how reimbursement and proof work.

By Joe Rosenblatt · Founder & ICHRA Broker, The ICHRA Broker

Key facts

Governed by
IRS Publication 502 expenses
Premiums?
Yes for ICHRA/QSEHRA; varies by type
Proof required
Yes — substantiation
Set by
The employer's plan design

What HRAs generally reimburse

  • Health insurance premiums (for ICHRA and QSEHRA; many integrated HRAs exclude premiums)
  • Doctor visits, copays, coinsurance, and deductibles
  • Prescription medications
  • Dental care and orthodontia
  • Vision care, exams, glasses, and contacts
  • Mental health and therapy
  • Many over-the-counter items and medical supplies

Premiums vs. medical expenses

The single biggest distinction is whether an HRA reimburses insurance premiums or only out-of-pocket medical expenses. ICHRA and QSEHRA can reimburse individual premiums; integrated (group-coverage) HRAs typically reimburse out-of-pocket costs like deductibles and copays rather than premiums. Always confirm which your specific HRA covers.

The eligible expense list

Eligible medical expenses are defined by IRS Publication 502 — the same list that governs HSAs and FSAs. It''s broad, covering most medically necessary care: physician and specialist visits, hospital services, lab work, prescriptions, dental, vision, mental health, physical therapy, medical equipment, and more. The employer can choose to cover the full list or narrow it in the plan design.

It depends on the plan design

Within IRS limits, the employer decides what a specific HRA covers. Some HRAs reimburse only premiums; others cover the full range of Publication 502 expenses. So two HRAs can have different eligible-expense lists — always check your plan''s specific rules rather than assuming.

What''s typically NOT eligible

  • Cosmetic procedures without a medical purpose
  • General wellness items without a medical need (most gym memberships, supplements)
  • Expenses already reimbursed by insurance or another account
  • Non-qualified personal expenses

Over-the-counter items

Many over-the-counter medications and health products are eligible without a prescription, along with items like menstrual care products and certain medical supplies. The specifics can shift with regulation, so a current eligible-expense list from your administrator is the reliable reference.

How reimbursement and proof work

You pay the expense, submit documentation (a receipt or proof of coverage), and the employer reimburses you tax-free — typically through payroll or an administration platform. Keeping good records is the key to smooth, compliant reimbursement, and substantiation is what preserves the tax-free treatment.

Section 213(d): the master reference

The universe of eligible medical expenses follows IRS Section 213(d), the same reference used by HSAs and FSAs. It covers a broad range of medical, dental, and vision costs. Whether a given HRA reimburses all of it or just premiums depends on how the plan is written.

Reimbursing family members' expenses

Most HRAs can reimburse qualified expenses not just for the employee but for their spouse and tax dependents, when the plan is written to allow it. That makes an HRA a meaningful benefit for employees with families, not just individuals.

How plan design sets the boundaries

The eligible list is ultimately a design choice. A premium-only HRA reimburses just insurance premiums; a full-medical HRA also covers out-of-pocket costs under 213(d). Employers pick the scope when they set up the plan, so always check what your specific HRA is written to cover.

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Frequently asked questions

Commonly: health insurance premiums (for ICHRA/QSEHRA), copays, deductibles, prescriptions, dental, vision, and mental health care, plus many IRS Publication 502 medical expenses — subject to the employer''s plan design.

JR

Joe RosenblattFounder & ICHRA Broker, The ICHRA Broker

Joe Rosenblatt is the founder of The ICHRA Broker, an independent ICHRA brokerage that helps small businesses offer tax-free health benefits without a group plan. He works directly with employers and their advisors on ICHRA and QSEHRA setup, plan design, and compliance.

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