Short answer: No. An HSA is individually owned and generally isn’t an ERISA plan, so it triggers no Form 5500. A QSEHRA can be an ERISA welfare plan, but because QSEHRAs are limited to employers with fewer than 50 employees, it falls under the small-plan exemption (fewer than 100 participants) and isn’t required to file either.
Employers offering only HSAs or a QSEHRA generally don’t have to file Form 5500, though for slightly different reasons.
An HSA is an individually owned account. As long as the employer limits its role to making contributions and running payroll deductions, and does not control the accounts, it is not an ERISA-covered plan, so no Form 5500 is required (DOL Field Assistance Bulletin 2004-01).
A QSEHRA is less clear-cut: it can be an ERISA welfare benefit plan. But ERISA’s small-plan exemption excuses any unfunded or insured welfare plan with fewer than 100 participants at the start of the plan year from filing, and QSEHRAs are only available to employers with fewer than 50 employees, so they fall within that exemption. If the employer also offers other ERISA benefits that reach the 100-participant threshold, a Form 5500 may still be required for those.