Employers need to know exactly what the membership covers and who pays for anything else. Decide in advance whether extras like labs, medications and procedures are included, billed to the employee or billed to the employer. Then show them on their own lines in your books.
Three ways to handle extras
- Included in the employer's monthly fee. Simple for employees, but your cost per member rises with use.
- Billed to the employee at your member prices. The employer's cost stays fixed.
- Billed to the employer on the monthly invoice. Employees aren't surprised, but the employer's invoice changes each month.
Watch the HSA rules
If an employer relies on its employees keeping HSA eligibility, extras matter. IRS Notice 2026-5 says the only payment for the care a qualifying arrangement covers must be its fixed periodic fee. It also says a practice can offer other services to members and non-members and bill them separately. Where your extras fall is a question for your healthcare attorney. Here's the summary.
Price included extras with care
If labs are included, they're part of your cost per member. In a made-up example, included labs cost you an average of $6 per member per month. On a 60-member contract, that's $360 a month. If the group uses twice as many labs as your average member, it's $720. Build it into your floor price.
Billing extras to the employer
- Show extras as a separate section of the invoice, with totals only.
- Don't list which employee had which lab or medication. Here's why.
- Agree in writing what the employer is willing to pay for.
In your books
Record lab and medication revenue on their own lines, apart from membership revenue, and the matching costs on their own expense lines. That's how you see whether extras make or lose money. This post covers meds and labs.
What I'd do this week
- List every extra you offer and how each employer contract handles it.
- Check that lab and medication revenue have their own lines in your books.
- Ask your attorney whether your extras fit the HSA rules for employers who rely on them.
Common questions
Should employer contracts include labs?
It depends on your costs and the employer's budget. If you include them, build their cost into the price and watch the group's use.
Can I mark up labs and meds for employer members?
Decide your markup in advance. Use the same prices for employer and individual members, and check any state rules with your attorney.
What if an employee disputes a charge?
Have the price list in writing and share it at enrollment.
Want to see whether extras make or lose money?
We reconcile every account every month and send your P&L and Balance Sheet by the 15th, so decisions like this start from real numbers. If that's what you need, apply to work with us.