What counts toward minimum value: employer HSA contributions, qualifying HRAs and tobacco wellness credits.
The regulation lets employers count certain contributions when testing a plan for minimum value. HSA contributions, qualifying HRA amounts and tobacco-related wellness incentives count, and other wellness incentives do not.
This guide lists the conditions. The overview is the MEC vs MV guide and the test itself is in the 60 percent test. Send us your renewal and we will model your plan.
What the regulation allows.
Employer HSA Contributions
Employer contributions to health savings accounts for the current plan year count toward the minimum value percentage.
Qualifying HRAs
Employer HRA contributions count only if the HRA is offered by the same employer, may reduce only covered medical cost sharing and the amount is required by the plan terms or determinable before enrollment.
Wellness Incentives
Tobacco-related incentives count as earned. Other wellness incentives do not.
Counts or does not count.
| Input | Counts | Condition |
|---|---|---|
| Employer HSA contribution, current plan year | Yes | Employer contribution. |
| Employer HRA contribution | Yes, if conditions are met | Same employer, covered medical cost sharing only, amount known before enrollment. |
| Tobacco-related wellness incentive | Counts as earned | Treated as earned. |
| Other wellness incentive | No | Does not count. |
Three questions about inputs.
Can an HRA that reimburses premiums count?
The regulation limits counting to HRAs that may reduce only covered medical cost sharing.
Is the HSA contribution counted for prior years?
The regulation refers to contributions for the current plan year.
Does a nonsmoker credit count?
The regulation treats tobacco-related wellness incentives as earned. Other wellness incentives do not count.
Where these figures and rules come from.
26 CFR 1.36B-6
The minimum value standard and how contributions count are in 26 CFR 1.36B-6.
Related guides.
Minimum Essential Coverage vs Minimum Value
The main guide to the two standards.
Minimum Value and Network Type
How network design interacts with the test.
The 60 Percent Test
What minimum value measures.
Penalty A vs Penalty B
How the two employer penalties differ.
ICHRA vs QSEHRA vs HRA
Choosing among the individual-coverage arrangements.
Coverage Tiers Explained
EE, ES, EC and EF in plain terms.
Send us your renewal.
Four documents — the renewal letter, the plan summary, the contribution split by tier and enrolled counts by tier. We’ll come back with a competitive read, where we see opportunity, and the five questions we’d put to your carrier.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →
Cookies on This Site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential — needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics — tell us which pages get read, so we know what is worth writing more of.
- Advertising — set by third parties such as ad and social platforms to measure and target campaigns.