You already know the self-employed deduction better than most people reading this, so this skips the basics and goes to the parts that trip up firms: seasonal staff, partners who assume they can join the plan they set up for employees, and what changed in 2026.
Who the CPA firm can cover
Staff accountants, bookkeepers and admin on a W-2 are employees.
Partners with a K-1 are self-employed and cannot participate in the firm’s QSEHRA or ICHRA. Shareholders owning more than 2% of an S corporation are in the same position for fringe benefits: the premium runs through their W-2 and they take the deduction themselves.
Seasonal preparers are employees too, which is where the design choices come in.
Three ways to pay for staff
Across the 23 states I work in, median pay for staff accountants from $64,170 to $90,030, bookkeepers from $40,070 to $54,080 and seasonal tax preparers from $33,390 to $62,860 (BLS, May 2024). That spread decides which option works.
A QSEHRA reimburses employees tax-free for individual coverage they buy, up to $6,450 for self-only and $13,100 for family coverage in 2026. It is for employers with fewer than 50 full-time-equivalent employees that offer no group plan, it has to be offered on the same terms to every eligible employee, and a shareholder owning more than 2% of an S corporation cannot use it.
An ICHRA — HealthCare.gov now calls it a CHOICE Arrangement, though the IRS still uses the old name — has no cap and no size limit. You set amounts by class of employee (full-time, part-time, seasonal, salaried, hourly, location and a few others), and within a class the amount can rise with age, up to 3 to 1, and with family size. Employees must be enrolled in individual coverage to use it. An offer that leaves the lowest-cost Silver plan costing an employee more than 9.96% of household income in 2026 is unaffordable, and that employee can decline it and take a premium tax credit.
A small-group plan puts everyone on one policy and one network, with participation and contribution minimums set by the insurer. It is still the right answer when the team is older or someone needs a specific specialist network, and it is the only route to the Small Business Health Care Tax Credit, which runs through SHOP.
Tax season staff
A QSEHRA can exclude seasonal and part-time employees, and so can an ICHRA through separate classes, but the two handle it differently. A QSEHRA must be offered on the same terms to every eligible employee it does not exclude. An ICHRA can put seasonal staff in their own class with their own amount, or leave them out entirely while funding full-time staff. If you run both a group plan and an ICHRA for different classes, minimum class-size rules apply, so check the headcount before you split.
What works for different firms
- Sole practitioner, one bookkeeper. You on an individual policy (Form 7206); the bookkeeper on a QSEHRA.
- Two partners, five year-round staff, four seasonal. Partners on their own policies; a QSEHRA or ICHRA for year-round staff that excludes the seasonal class.
- Firm growing past 20. Price an ICHRA with full-time and part-time classes against a small-group plan.
What changed in 2026
Three things matter to anyone in a CPA firm. The enhanced premium tax credits ended, so subsidies stop again at 400% of the poverty line: $62,600 for one person and $128,600 for a family of four. Starting with the 2026 tax year there is no cap on paying back excess advance subsidy, which falls hardest on anyone whose income moves around. And bronze and catastrophic plans now count as HSA-eligible, so an owner on a bronze plan can put $4,400, or $8,750 for a family, into an HSA.
CPA Firms by state
- Alabama
- Arkansas
- Colorado
- Florida
- Georgia
- Illinois
- Indiana
- Kansas
- Maryland
- Michigan
- Mississippi
- Nebraska
- Nevada
- North Carolina
- Ohio
- Oklahoma
- South Carolina
- South Dakota
- Tennessee
- Texas
- Utah
- Virginia
- Wisconsin
Sources: HealthCare.gov, CHOICE Arrangements (formerly individual coverage HRAs); IRS Notice 2017-67, Qualified Small Employer HRAs; IRS Publication 15-B (2026), Employer’s Tax Guide to Fringe Benefits; IRS, S corporation compensation and medical insurance issues; IRS, Instructions for Form 7206, Self-Employed Health Insurance Deduction; IRS, One Big Beautiful Bill provisions; IRS Notice 2026-5, Expanded availability of health savings accounts; U.S. Bureau of Labor Statistics, Occupational Employment and Wage Statistics, May 2024.
Questions owners ask
Can a CPA firm exclude seasonal tax preparers from its health reimbursement?
Yes. A QSEHRA may exclude seasonal and part-time employees, and an ICHRA can place seasonal staff in a separate class with its own amount or no offer at all.
Can CPA firm partners join the firm’s QSEHRA?
No. Partners are self-employed, not employees, and more-than-2% S corporation shareholders are treated the same way for fringe benefits. They deduct their own premiums on Form 7206.
What is the 2026 QSEHRA limit?
$6,450 for self-only coverage and $13,100 for family coverage, per IRS Publication 15-B for 2026.