Health Benefits Policy

Effective Date: 01 January 2026
Purpose: Neuromatch is committed to supporting the health and wellbeing of its employees through equitable, compliant, and financially sustainable health benefit arrangements. This policy defines employee eligibility and the mechanisms through which health benefits are provided for U.S.-based and international employees.

1. General Principles

  • Neuromatch provides health benefits to eligible employees only. Independent contractors, consultants, advisors, volunteers, and other non-employee workers are not eligible for health benefits under this policy, regardless of hours worked or duration of engagement.
  • Health benefits are offered through mechanisms that comply with applicable local, national, and international employment and tax laws.
  • Benefit structures and reimbursement limits are reviewed annually and may be adjusted based on regulatory changes, financial sustainability, and organizational priorities.

2. Eligibility

To be eligible for health benefits under this policy, an employee must:
  • Hold a regular appointment of at least 60% full-time equivalent (0.6 FTE), and
  • Meet any additional eligibility requirements imposed by the applicable benefit mechanism or local law.
Eligibility is assessed based on the employee’s current approved level of effort and may change if effort falls below the eligibility threshold.

3. U.S.-Based Employees — QSEHRA

3.1 Benefit Mechanism

Neuromatch provides health benefits to eligible U.S.-based employees through a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA), in accordance with U.S. federal regulations. Neuromatch does not sponsor or administer group health insurance plans.

3.2 Scope of Reimbursable Expenses

Under Neuromatch’s QSEHRA plan design:
  • Reimbursement is limited to health insurance premiums for qualifying health insurance coverage, as permitted under IRS regulations.
  • Eligible premiums include:
  • Individual health insurance plans purchased through the ACA marketplace or directly from insurers
  • Employer-sponsored health insurance obtained through a spouse or domestic partner
  • Former-employer coverage, including COBRA continuation coverage and retiree health plans
  • Neuromatch does not reimburse out-of-pocket medical expenses, including but not limited to copays, deductibles, coinsurance, prescriptions, dental services, or vision services.
  • Premiums for spouses, domestic partners, and dependents may be eligible for reimbursement only where the employee is enrolled in family coverage under a qualifying health insurance plan.
  • All reimbursements under the QSEHRA — including amounts attributable to employee coverage and any covered dependents — count toward the employee’s total permitted benefit amount (annual and monthly cap).
  • Premiums or medical expenses incurred by spouses, domestic partners, or dependents are not eligible for reimbursement, even if the employee is enrolled in family coverage.
This premium-only, employee-only reimbursement structure applies uniformly to all eligible employees.

3.3 Permitted Benefit Amount (2026)

For the 2026 calendar year, the maximum permitted reimbursement amount under the QSEHRA is $5,715 USD per year ($476.25 USD per month) per eligible employee.
This permitted benefit amount represents the total maximum reimbursement available to the employee, including any reimbursement for eligible premiums covering spouses, domestic partners, or dependents under family coverage.
Reimbursement limits are subject to annual review and adjustment in accordance with IRS regulations and organizational planning.

3.4 Reimbursement Administration

Reimbursements are processed on a monthly basis (via Rippling) via submission of receipts for eligible expenses and in compliance with QSEHRA administrative requirements.
Reimbursements may be prorated based on:
  • Start or end date of employment
  • Changes in FTE status
  • Changes in eligibility during the calendar year
Total reimbursements may not exceed the annual permitted benefit amount.

4. International Employees — Employer of Record (EoR)

For employees hired outside the United States through an Employer of Record (EoR) arrangement:
  • Health benefits will be provided in accordance with local statutory requirements in the employee’s country of employment.
  • Where required by law, Neuromatch will provide mandatory health coverage or contributions in accordance with local regulations; where discretion is permitted, Neuromatch will aim to provide health benefits broadly equivalent in value to those offered to U.S.-based employees, unless local law requires a more generous provision, in which case local legal requirements will prevail.
  • Coverage for dependents will be provided only where required by local law.
Specific benefit structures may vary by country and EoR provider and will be communicated individually to employees.

5. Exclusions

Neuromatch does not offer:
  • Reimbursement of out-of-pocket medical expenses
  • Health benefits to employees below 60% FTE
  • Cash alternatives in lieu of health benefits
  • Employer-sponsored group health insurance plans for U.S.-based employees

6. Policy Review and Amendments

This policy is reviewed annually, typically in advance of each calendar year, to account for:
  • Regulatory changes
  • Updates to QSEHRA statutory limits
  • Organizational financial planning and sustainability
Neuromatch reserves the right to amend, replace, or discontinue this policy at any time, subject to applicable law. Employees will be notified in writing of any material changes.