My client is an S-corp. It would like to establish a medical reimbursement plan for only 2% shareholders (all employees are 2% shareholders). What are its options, if any?

Is it possible for the S-corp. to establish a medical reimbursement plan that is not part of a Sec. 125 plan and not an HRA or health FSA, that can provide medical reimbursement benefits to the employees?

Thanks in advance for your comments.