What is the difference between an HSA and an HRA?

An HSA is a tax-advantaged savings account that employees and employers can contribute to, up to the annual maximum limit. An employer can offer an HSA as part of their company’s benefits package, or an individual can open one on their own. In either case, the individual always owns it and the funds inside — even if they leave their employer’s organization. An HRA is a personalized health benefit that lets employers contribute tax-free money toward employees’ individual health plan premiums. With a CHOICE Arrangement, there are no minimum or maximum contribution limits. HSA funds roll over annually and remain with the employee indefinitely, while unused HRA funds remain with the employer at the end of the plan year or if an employee leaves their company.

Can you use HSA funds for health insurance premiums?

You can’t use your HSA to pay for individual or group health insurance premiums. However, the IRS allows account holders to pay premiums for COBRA coverage, health coverage while receiving unemployment compensation, qualified long-term care insurance, and Medicare Parts A, B, C, and D after age 65. If your employer offers a CHOICE Arrangement, they can design the benefit to allow tax-free payments toward employees’ individual health plan premiums.

Can you have an HSA and an ICHRA at the same time?

Yes. An HSA can pair with an ICHRA, now called the CHOICE Arrangement, if the plan design meets HSA eligibility rules. This means the CHOICE Arrangement must limit reimbursement to employees' health insurance premiums, as well as dental and vision expenses. Alternatively, employers can limit the ICHRA to reimburse out-of-pocket expenses only after employees reach their deductibles. A standard ICHRA can make an employee ineligible for an HSA because it could reimburse all qualified healthcare costs outlined in IRS Publication 502.

What happens to your HSA if you change jobs?

Your HSA stays with you when you leave an employer. You keep the account balance, including any employer contributions deposited, and can continue using the funds for qualified medical expenses. You can contribute to the account at a new job or on your own.

What happens to HSA funds you don't use by the end of the year?

Unlike a health FSA, unused HSA money rolls over automatically from year to year. You don't have to spend the funds by December 31, and you can continue saving or investing eligible funds for future healthcare expenses.

How do you calculate FTEs for ACA purposes?

For each month, count your full-time employees (those who average at least 30 work hours a week) and add the full-time equivalent represented by your non-full-time employees. To calculate non-full-time FTEs, add their monthly work hours, limit each employee to 120 hours, and divide the total by 120. Then average the monthly totals over 12 months and round the result down to the nearest whole number.

How many FTEs make an organization an ALE?

An employer is generally an ALE if it averaged at least 50 full-time employees, including FTEs, during the previous calendar year.

Do part-time employees count toward the 50-employee ACA threshold?

Yes. Although they don’t work on a full-time basis, you must combine the hours your part-time employees work with those of your full-time employees to determine whether the total reaches the 50-employee ALE threshold.

Do seasonal employees count when calculating ALE status?

Yes, you must include seasonal employees in the calculation, unless you qualify for the seasonal worker exception. To qualify, your workforce must exceed 50 full-time employees (including FTEs) for no more than 120 days during the calendar year, and the employees above the 50-employee threshold during that period are seasonal workers.

What happens if my company becomes an ALE?

If your organization becomes an ALE, it becomes subject to the ACA's employer shared responsibility provisions. This means the employer must offer affordable, minimum-value coverage to at least 95% of its full-time employees and their dependents, or it may owe one of the two employer shared responsibility payments, which can be very costly.

What does an ICHRA provider do?

An ICHRA provider helps employers design, implement, and administer their individual coverage health reimbursement arrangement. Depending on the provider, services may include compliance support, employee enrollment assistance, plan selection tools, contribution management, reimbursement administration, payroll system or HRIS integrations, and ongoing customer support.

How do I choose an ICHRA vendor?

During ICHRA vendor selection, consider the level of administrative and compliance support, employee plan-selection and enrollment tools, technology integrations, broker support, customer service, and the provider's experience with businesses similar to yours. Employers should also consider whether they need a software-focused solution or a full-service ICHRA partner.

How much does it cost to administer an ICHRA?

ICHRA administration costs vary by provider and typically depend on factors such as the number of employees, services included, and level of support. Some providers primarily offer technology and automated administration, while others provide additional implementation, benefits advisory, compliance, and employee support services.

Can an employer switch ICHRA providers?

Yes. Employers can transition from one ICHRA provider to another. However, the change requires careful coordination to keep employee, contribution, plan, and reimbursement information accurate. Employers should work with their current and new providers to establish a transition timeline and communicate any changes to employees and brokers.

Was ICHRA renamed to the CHOICE Arrangement?

Yes. On September 3, 2026, CMS and the SBA announced that individual coverage health reimbursement arrangements (ICHRAs) would now be called CHOICE Arrangements. The name change didn’t fundamentally change how the employee benefit works; the existing ICHRA framework remains in place under the new name. Employers and benefits professionals may still encounter the term ICHRA because it remains common in the health benefits landscape and existing plan materials.

Is a CHOICE Arrangement cheaper than traditional group health insurance?

A CHOICE Arrangement can help employers control and predict their health benefits spending because the employer determines the contribution amount rather than paying the premium for a specific group health plan. However, costs depend on the employer's contribution strategy, workforce demographics, locations, and individual insurance market. Remodel Health can help you design a compliant CHOICE Arrangement that fits your budget.

How does a CHOICE Arrangement work for employees?

Employees receiving a CHOICE Arrangement contribution shop for and enroll in qualifying individual health insurance coverage. They can compare plans based on factors such as premiums, deductibles, provider networks, prescriptions, and expected healthcare needs. The employer then provides the defined contribution that employees can use toward their monthly plan premiums.

Can an employer offer both a CHOICE Arrangement and a group health plan?

Yes, an employer may offer a CHOICE Arrangement and traditional group health insurance at the same time. But under federal rules, employers must ensure employees in a specific class can access only one type of benefit. You can’t give your staff within the same class a choice between the group plan and the CHOICE Arrangement. For example, an organization could structure its benefits so that hourly employees receive group coverage while salaried workers receive a CHOICE Arrangement.

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. Additionally, employees with a CHOICE Arrangement who enroll in an HSA-eligible health plan can use their tax-advantaged HSA funds to pay for DPCSA membership fees, as long as the total doesn’t exceed $150 per month for an individual or $300 per month for a family.

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.

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.

What is the difference between Medicaid and CHIP?

Medicaid provides health coverage for eligible low-income individuals and families, including adults, children, pregnant individuals, seniors, and people with disabilities. In contrast, CHIP is primarily for children and certain pregnant individuals whose household income is too high to qualify for Medicaid but too low to comfortably afford private health insurance.

Can you have Medicaid and private health insurance at the same time?

Yes. In some situations, individuals can have Medicaid and another form of health insurance simultaneously. When this happens, Medicaid may help pay for certain medical costs the primary insurance plan doesn’t cover. However, coordination of benefits rules may vary depending on the type of private coverage the individual has and their state requirements.

What income levels qualify for Medicaid?

Medicaid income limits vary by state, household size, and eligibility category. Most states use modified adjusted gross income (MAGI) to determine eligibility for children, parents, and many adults. In states with Medicaid expansion due to the Affordable Care Act (ACA), adults with household incomes up to 138% of the federal poverty level may qualify.

Can adults qualify for CHIP?

CHIP is primarily for children younger than age 19. However, some states allow certain pregnant individuals to qualify for CHIP coverage.

Can employees with Medicaid participate in an ICHRA?

No. While Medicaid counts as minimum essential coverage (MEC), the federal government doesn’t consider it qualifying individual health insurance, which is necessary to participate in an ICHRA. Employees must enroll in an eligible individual health plan to use their ICHRA benefit.

Does an ICHRA affect CHIP eligibility?

It can. A child's eligibility for CHIP may depend on whether the employee's ICHRA meets affordability standards. Because CHIP rules differ by state, employees should contact their state's Marketplace or Medicaid agency to determine how an ICHRA offer affects their family's eligibility.

Elizabeth Walker

Elizabeth Walker is a content marketing specialist at Remodel Health and PeopleKeep. Since starting with the company in April 2021, she has become well-versed in writing about HRAs, health benefits, and small business solutions. Outside of her expertise in the healthcare benefits industry, Elizabeth has been a writer for more than 20 years and has written several poems and short stories. She's published two children’s books in 2019 and 2021, which she is developing into a series of collected works. Her educational background as a classical musician and love of the arts continue to inspire her writing and strengthen her ability to be creative.

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