Can employees use a CHOICE Arrangement to pay for individual dental or vision insurance?

Yes, employees can use a CHOICE Arrangement to pay for individual dental and vision insurance premiums or out-of-pocket costs, if their employer's plan design allows for it.

Can a small business offer a CHOICE Arrangement and a QSEHRA at the same time?

No. An employer generally can't offer both a CHOICE Arrangement and a QSEHRA to the same employees. Small businesses should evaluate which HRA best fits their benefits strategy.

Can employers offer a CHOICE Arrangement and an HSA at the same time?

Yes, but certain requirements apply. To contribute to an HSA, an employee needs an HSA-eligible HDHP, and the CHOICE Arrangement must be structured to avoid providing disqualifying coverage.

Does direct primary care replace health insurance?

No. Direct primary care generally covers primary care services but isn't health insurance. Individuals must purchase separate health insurance if they need coverage for other medical services, such as hospitalization, specialist care, and surgery.

Is direct primary care worth it?

It can be, especially for individuals who want access to routine care at an affordable, fixed price. However, those who need acute care and have the budget may want to consider enrolling in a major medical plan for emergency care or for chronic disease management.

Can you have a CHOICE Arrangement and direct primary care at the same time?

Yes. An employer can offer a CHOICE Arrangement and provide employees with access to a direct primary care membership. But employees who want to participate in the CHOICE Arrangement must still obtain qualifying individual health coverage to use the benefit; they can’t only have DPC.

Can a CHOICE Arrangement pay for direct primary care?

DPC membership payments are ineligible for reimbursement under a CHOICE Arrangement. This is because employees must enroll in ACA-compliant individual health insurance to use a CHOICE Arrangement, and DPC doesn’t count as individual coverage. However, depending on the plan design, a CHOICE Arrangement can reimburse many health expenses that DPC providers offer, such as annual physicals, clinical services, and flu vaccines.

Can you use an HSA with direct primary care in 2026?

Yes, as of January 1, 2026, individuals who have a DPC membership can contribute to an HSA and use their tax-free HSA funds to pay their DPC fees. However, under federal requirements, DPC fees must not exceed $150 per month for individuals or $300 per month for families to be eligible for HSA payment.

Was ICHRA renamed CHOICE?

Yes, CMS and the SBA announced that ICHRA is now called the CHOICE Arrangement during an event at Hancock Wellness Center in New Palestine, Indiana, on September 3, 2026. Remodel Health representatives were invited to participate in this announcement.

How does ICHRA’s renaming impact the benefit?

CMS renaming ICHRA as the CHOICE Arrangement should have little to no impact on how the ICHRA functions. The CMS and SBA announcement only shared a rebrand without new features, though additional changes could be on the way. The same Final Rules that currently apply to ICHRA still apply to the CHOICE Arrangement.

Should I start referring to ICHRA as the CHOICE Arrangement in communications with clients or employees?

Yes, we recommend using the new name and explaining that it was formerly called ICHRA in any conversations with clients or employees. Since the federal government is officially retiring the ICHRA name, it’s best to start using the CHOICE Arrangement in practice. However, we predict that both terms will be used interchangeably for the foreseeable future.

Do I need to update my plan documents right now?

CMS hasn’t shared any compliance deadlines for plan documents due to the rename.

Does this affect ACA employer shared responsibility provision compliance?

CMS did not announce any changes to affordability or minimum value rules for CHOICE Arrangements, previously known as ICHRA. The underlying compliance framework remains unchanged.

Does the CHOICE Arrangement impact QSEHRA?

No, ICHRA becoming CHOICE doesn’t impact the qualified small employer health reimbursement arrangement (QSEHRA). The QSEHRA is a stand-alone HRA for small businesses with fewer than 50 full-time equivalent employees (FTEs). Since Congress created QSEHRA, CMS’s actions don’t impact the benefit. It only applies to ICHRA.

When does this change to CHOICE take effect?

ICHRA became the CHOICE Arrangement immediately after the announcement. However, it will take time for the general public to stop using the ICHRA name in favor of CHOICE.

Did the CHOICE Arrangement replace ICHRA?

The CHOICE Arrangement replaced the ICHRA name as of September 3, 2026. All ICHRA rules remain unchanged under the CHOICE Arrangement. If you already offer an ICHRA, you shouldn’t experience any disruption to your benefits.

Does the CHOICE Arrangement change how ICHRA works?

No. There are no immediate changes to the ICHRA with the new CHOICE Arrangement name.

Are employers required to switch from ICHRA to the CHOICE Arrangement?

No. The ICHRA final rules remain intact, so ICHRA plans that are current as of January 1, 2026, will continue to exist for the duration of their plan year. There’s no need for midyear changes or readoption. The federal government has simply rebranded ICHRA as the CHOICE Arrangement. Operationally, the two benefits are identical. Any additional requirements or enhancements would apply prospectively and would likely be implemented through future regulatory guidance.

Is ICHRA software enough to administer an ICHRA?

It can be, depending on your team's resources and the software provider's capabilities. ICHRA software can automate many administrative tasks, but your team may still be responsible for plan setup, employee questions, compliance, documentation, and ongoing administration. Employers with experienced benefits staff may be comfortable managing these responsibilities internally.

Is full-service ICHRA administration more expensive than software?

Full-service administration typically costs more than software alone because you're paying for both technology and professional support. However, the total cost should also account for the time your internal team spends managing the ICHRA. For growing companies with lean HR teams, outsourcing more administrative tasks can reduce internal workload and free up time for other priorities.

Is full-service ICHRA administration better for growing companies?

Full-service administration can be a strong fit for growing companies because ICHRA administration can become more complex as an organization adds employees, expands into new states, or develops more nuanced benefits strategies. Having technology and dedicated benefits professionals can help employers scale their ICHRA without putting all of the additional administrative work on their HR team.

When is ACA Open Enrollment?

Currently, Open Enrollment runs from November 1 through January 15 in most states using the federal Marketplace. Enrolling by December 15 allows coverage to begin January 1, while enrolling between December 16 and January 15 means your health plan will take effect on February 1. To activate coverage, you must pay your first month’s premium by the deadline. State-based exchanges may have different deadlines, so check your state's Marketplace before enrolling in a health plan.

Can I change my health plan during Open Enrollment?

Yes. During Open Enrollment, you can enroll in a new Marketplace plan, switch plans, renew your current coverage, or make changes to your household coverage. Outside of Open Enrollment, you typically need to qualify for a special enrollment period to change an ACA health plan.

What happens if I miss Open Enrollment?

If you miss the Open Enrollment deadline, you must wait until the next Open Enrollment Period unless you qualify for a special enrollment period. Qualifying events can include losing other health coverage, getting married, having a baby, or an employer’s offer of a new health benefit, like an ICHRA.

Can I enroll in a health insurance policy outside of Open Enrollment?

You can enroll in a health plan outside of Open Enrollment if you’re eligible for a special enrollment period. If you don’t qualify for a special enrollment period, you may qualify for Medicaid or CHIP if you meet the eligibility requirements, or you can purchase short-term health insurance on a private exchange.

Do I have to enroll in individual health insurance to use an ICHRA?

Yes. To use an ICHRA, you must have a qualifying ACA-compliant individual health plan that provides minimum essential coverage (MEC), Medicare Parts A and B together, or Medicare Part C. Short-term health insurance and other limited benefits don't satisfy the individual coverage requirement for an ICHRA. If you have one of these plans, you can switch to a qualified health insurance policy during Open Enrollment so you can participate in your ICHRA benefit.

What is the difference between a Bronze, Silver, Gold, and Platinum health plan?

The main difference between the four metal tiers is how the plan divides costs between the insurer and the planholder. Bronze plans have an actuarial value of about 60%, and Silver has 70%. Gold coverage has an actuarial value of 80%, and Platinum has 90%. In general, higher-tier plans have higher premiums but lower out-of-pocket costs when you receive care.

Which metal tier is best for health insurance?

There isn't a single metal tier that's best for everyone, as consumers have varying healthcare needs. Bronze may work well for someone who wants a lower premium and doesn’t expect to use much healthcare during the plan year. Gold or Platinum might be a better fit for someone who expects higher medical expenses or has a chronic condition. Those searching for a middle-ground policy or needing cost-sharing reductions may find a Silver plan to be the best option.

Does a higher metal tier mean better health insurance?

No. Metal tiers describe how the plan will divide healthcare costs between you and the insurance company. They don't indicate the quality of your healthcare or guarantee a larger provider network. For example, a Bronze plan can provide the same health benefits as a Platinum plan; however, the cost-sharing structure will be different.

Can I use an ICHRA with a Bronze, Silver, Gold, or Platinum plan?

Yes. Employees with an ICHRA only need qualifying individual health insurance coverage to use the benefit, regardless of the plan’s metal tier. However, how the ICHRA and premium tax credits work together depends on your benefit’s affordability. If your ICHRA is affordable (meaning you’re not paying more than 9.96% of your actual income for the lowest-cost Silver plan on a public health exchange), you can't receive your premium tax credit. If it's unaffordable, you can opt out of the ICHRA and collect your tax credits.