Guide to the individual coverage HRA (ICHRA)
Whether you’re an employer, a broker, or an HR professional, this comprehensive guide will take you through everything you need to know about designing and managing an individual coverage health reimbursement arrangement (ICHRA). Learn how this flexible, tax-free health benefit empowers business owners to control costs while supporting their employees’ healthcare.
Take control of rising health insurance costs with an ICHRA
The rising cost of group health insurance has made offering traditional benefits more challenging than ever. Between skyrocketing premiums, rising self-insured costs, tight budgets, and one-size-fits-all group plans, applicable large employers (ALEs) are failing to meet the needs of their diverse workforces, especially if you have remote or multi-state employees.
The good news is that ALEs have a more affordable and flexible alternative to group plans. An ICHRA allows you to control your budget, comply with Affordable Care Act (ACA) regulations, and enable your staff members to choose their own health plan, regardless of their lifestyle or location.
In this guide, we’ll walk you through everything you need to know about the ICHRA, including how to design the benefit so that your company keeps costs stable and your employees experience greater engagement and satisfaction.
- Chapter 1: What is an ICHRA?
- Chapter 2: How does an ICHRA work?
- Chapter 3: What are the benefits of the ICHRA?
- Chapter 4: What are some key features of the ICHRA?
- Chapter 5: How does the ICHRA compare to group health insurance?
- Chapter 6: What are the steps to launching an ICHRA?
- Chapter 7: How to administer a compliant ICHRA
- Chapter 8: History of the ICHRA
- Chapter 9: Eligible ICHRA expenses
- Chapter 10: ICHRA FAQs
What is an ICHRA?
The ICHRA (pronounced “ick-ruh”) is a flexible, stand-alone health benefit available to employers of any size or industry with at least one W-2 employee. Instead of buying a traditional fully-insured group health plan or establishing a self-funded plan, employers with an ICHRA set a tax-free monthly allowance that employees can use to buy their own individual health coverage and, in some cases, qualified out-of-pocket medical expenses.
This defined contribution health benefit gives employees more choice and control over their healthcare, while allowing employers to maintain a reasonable benefits budget. This flexibility is why the ICHRA is gaining popularity as a way to offer meaningful employee health benefits without the high rate increases and costs of group plans.
Visit our ICHRA glossary to get familiar with key terms and definitions before you dive in.
How does an ICHRA work?
If you’re new to the ICHRA, it may seem like it’s difficult to understand — especially if you’re transitioning from group health insurance. However, the process is simpler than you might think. The following three steps will take you through the process.
Step 1: The employer sets a monthly contribution amount
Employers begin by determining a monthly, tax-free contribution amount that employees can use to purchase health insurance and other medical expenses. For greater flexibility, you can vary allowances by age, family status, or job-based employee class.
If you’re an ALE, the ACA requires you to offer affordable health coverage that meets minimum value standards and minimum essential coverage (MEC) to at least 95% of full-time workers and their dependents. An ICHRA can fulfill this requirement as long as your allowance makes your employees’ individual health coverage affordable. This is because qualifying individual health plans already satisfy the ACA’s MV and MEC standards.
For the 2026 plan year, the federal government considers health coverage affordable if an employee’s share of the premium for the lowest-cost silver plan (after applying their ICHRA allowance) doesn’t exceed 9.96% of their total household income. You can use safe harbors like the federal poverty line or W-2 wages to determine affordability.
Step 2: Employees get qualifying coverage
Employees must have an individual health plan that meets MEC standards to use the benefit. Offering the ICHRA to newly eligible employees is a qualifying life event. This will trigger a special enrollment period (SEP) and give your staff 60 days to shop for and enroll in a qualifying health plan on a public or private exchange so they can take advantage of the ICHRA. If you plan to offer an ICHRA that starts January 1, employees can also take advantage of the annual Open Enrollment period to enroll in or change their plan.
Qualifying coverage that’s eligible for the ICHRA includes:
- Medicare Parts A and B together
- Medicare Part C (Medicare Advantage)
- ACA-qualified individual health plans sold on public or private exchanges.
- Public exchanges include the federal Health Insurance Marketplace and state-based Marketplaces. Insurance carriers, licensed agents, and brokers are private exchanges.
- ACA-qualified student health insurance plans.
- Catastrophic health coverage (only for those younger than 30 or with a hardship exemption).
Plans that don’t count as qualifying individual coverage for the ICHRA include:
- A spouse’s or parent’s group health insurance policy
- COBRA
- Medicaid coverage
- Association health plans
- TRICARE
- Short-term health insurance
- Fixed indemnity policies
- Healthcare sharing ministries
Step 3: Payments or reimbursements for premiums and eligible medical services
Depending on the ICHRA administrator and how the benefit is set up, it can function in various ways.
For ICHRAs without payment solutions, once enrolled, employees pay out of pocket for qualified expenses such as insurance premiums, doctor visits, prescription medication, and other eligible healthcare costs. IRS Publication 502 and the CARES Act provide the complete list of more than 200 reimbursable items. However, you can limit this list in your ICHRA’s plan details if you choose. For example, you may decide only to reimburse your staff’s health insurance premiums to reduce costs.
When reimbursing employees, they must submit proper documentation, such as a receipt, invoice, or an explanation of benefits (EOB), to request reimbursement.
If an employer administers their ICHRA with a provider with payment solutions, like Remodel Health, things are more streamlined. Instead of reimbursing employees for premiums, employers deposit their monthly contributions into FDIC-insured accounts with overdraft protection for their employees. Then, Remodel Health automatically pays employees’ insurance premiums to the carrier.
For off-exchange plans, if the premium is more than the employee’s allowance, you can facilitate pre-tax withholding just like with a group plan. This eliminates the burden of employees bearing the brunt of the cost upfront. Our process has an industry-leading 99.7% accuracy rate for automated payments. The remaining 0.3% of payments is completed manually by our internal financial operations team.
All ICHRA reimbursements and payments are free from income taxes for employees and payroll tax-free for employers.
What are the benefits of the ICHRA?
From personalized coverage to predictable budgeting, the ICHRA is an effective way to meet the needs of today’s employees. But the advantages don’t stop there. Let’s review a few more benefits of the ICHRA in the sections below.
Personalized health coverage
The ICHRA allows employees to enroll in their own health insurance plan on the individual market and use their allowance to cover all or most of the premium. This means employees can choose the provider network, medical services, and policy type that best fit their needs and finances, rather than receiving the same coverage as their coworkers under a group health plan.
If an employee already has a qualifying health plan, they can keep it. Individual coverage is portable, so it will stay with them even if they change jobs (though they will lose their ICHRA contribution). If you partner with Remodel Health, your employees can compare and purchase off-exchange plans on our platform. They can also get help from our in-house benefits advisors and licensed Medicare experts.
Customizable plan designs
The ICHRA gives you the freedom to design a health benefit that fits your organization’s structure and workforce. For example, you can create employee classes — such as full-time, part-time, seasonal, or salaried — and offer different allowance amounts or eligibility rules to each group. You can also vary contributions based on age or family status.
These options enable you to create a benefits strategy that supports key employees and enhances overall satisfaction and retention.
No contribution limits or participation requirements
Unlike other HRAs, the ICHRA has no contribution limits. Employers can offer as much or as little as their budget allows. You also aren’t subject to minimum participation rates, unlike traditional benefit models that often require organizations to guarantee at least 70% employee enrollment. These features make it easier to scale your ICHRA as your workforce or financial situation changes, all while maintaining cost predictability.
Tax advantages
ICHRA reimbursements are exempt from payroll taxes for employers. They can also deduct their ICHRA contributions as a business expense for extra savings.
Additionally, employees don’t pay income taxes on ICHRA allowances or reimbursements. This means they can lower their overall taxable income while using ICHRA funds to cover necessary healthcare costs.
Financial savings
ICHRAs offer employers a fixed-cost approach to healthcare benefits. You set the allowance amount, and employees can’t exceed it. Any unused funds stay with you at the end of the plan year or if a participating employee leaves your company.
Because the ICHRA has no contribution limits, employers can adjust allowance levels during renewal time, maintaining full control over their benefits budget while avoiding unpredictable rate hikes. This makes the ICHRA a long-term solution to managing costs without compromising employee coverage.
What are some key features of the ICHRA?
One of the best aspects of the ICHRA is its customization abilities. Below are several ways to maximize key features of the ICHRA to improve its value for your employees.
Employee classes
Employee classes let you compliantly organize your workforce into groups so you can set different allowance amounts or eligibility rules. For example, during plan design, you can decide to contribute $400 per month to your seasonal employees and give your temporary workers a $300 monthly allowance.
Employers can choose from 11 job-based employee classes, including:
- Full-time employees
- Part-time employees
- Seasonal employees
- Temporary staff of staffing firms
- Salaried employees
- Non-salaried employees
- Employees covered under a collective bargaining agreement
- Employees in a waiting period
- Foreign employees working abroad
- Employees in different geographic areas (such as different states or rating regions)
- A combination of two or more of the above
All employees within the same class must receive the benefit on equal terms to satisfy federal nondiscrimination requirements. However, you can still differ contributions within each class by age or family status.
Age banding
Employers can also vary ICHRA allowance amounts based on employee age. This feature helps ensure that older employees receive fairer financial support, as insurance premiums and the need for medical care often increase with age.
Federal rules allow age-based differences as long as the highest allowance doesn’t exceed three times the lowest amount (a 3:1 ratio). Employers must apply these adjustments consistently within each class to comply with nondiscrimination laws.
Family status
In addition to employee classes and age customizations, employers may also adjust contributions based on family size. For instance, within a single employee class, you could provide a larger allowance for employees with families than for single employees since employees covering dependents often face higher insurance costs.
Just like with age banding, federal rules require that all employees within the same class receive the benefit on equal terms, ensuring fairness throughout similar groups of workers.
Coordination with other health benefits
The ICHRA can work alongside certain other health benefits, giving you the ability to create a robust compensation package that can better attract and retain talented employees.
Below are three examples of how the ICHRA coordinates with other benefits:
- Group health insurance. You can offer an ICHRA and a group health plan at your company as long as you do so compliantly. This means you can offer a traditional group plan to one employee class (such as full-time staff) and an ICHRA to another (like part-time workers). However, employees within the same class can’t choose between the two benefits. You also can’t offer both benefits to the same class.
- Group ancillary benefits. ICHRAs can pair with other group ancillary coverage, like dental and vision insurance plans. Suppose you don’t offer these policies at your organization. In that case, your employees can purchase their own coverage for these benefits and use their ICHRA funds to help pay for the premiums (if your plan design includes them as eligible expenses). For brokers, this means you can set your clients up with an ICHRA and still write their ancillary lines of coverage.
- Health savings accounts (HSAs). Employees can contribute to an HSA if their ICHRA only reimburses insurance premiums and they enroll in an HSA-eligible high-deductible health plan (HDHP). If your ICHRA reimburses premiums plus other medical expenses, employees can’t contribute to their HSA at the same time. They can contribute to their HSA again once they’re no longer participating in the ICHRA that reimburses for out-of-pocket expenses.
How does the ICHRA compare to group health insurance?
Under a fully-insured traditional group plan, employers purchase a policy from an insurance carrier and typically cover most of the premium cost for their employees. According to KFF, the average annual premiums were approximately $9,325 for self-only coverage ($777/month) and $26,993 for family coverage ($2,249/month) in 2025. Even for large employers with greater budgets and resources, annual rate hikes, complex carrier negotiations, and limited plan options are making group coverage less than desirable for today’s workforces.
Some employers turn to self-funded options as an alternative to traditional group health insurance. Instead of paying a fixed premium to an insurer, self-funded health coverage allows employers to design their own policy. However, they’re responsible for paying employees’ medical claims directly. Employers can buy stop-loss insurance to protect against catastrophic claims. But even so, administrative costs and plan management responsibilities can still be high.
The chart below compares the ICHRA to both group health benefit options:
|
ICHRA |
Traditional group plans |
Self-funded group plans |
|
|
Who can offer it? |
Employers in any industry who have at least one W-2 employee. The ICHRA can be a stand-alone benefit or work alongside traditional group health coverage as long as the employer offers it to separate employee classes. |
Employers who meet the carrier’s minimum participation requirements. |
Any size employer can self-fund. But larger organizations are best suited due to the potential for significant financial risk. |
|
Employee eligibility |
Employees must have qualified individual health coverage to participate. They must be W-2 employees. 1099 contractors, S corp 2% or more shareholders, owners of a partnership, and sole proprietors can’t participate. |
Employers define eligibility within the carrier’s limitations and ACA requirements. |
Employees must meet ACA nondiscrimination and eligibility rules. |
|
Enrollment |
Employees get a 60-day special enrollment period (SEP) to buy individual coverage when first offered an ICHRA, if offered midyear. They can change their qualifying individual health plan during the annual Open Enrollment Period or if they trigger a SEP with a qualifying life event. |
Employers typically hold a company-wide annual open enrollment period. Employees can only make changes outside of that time frame if they have a qualifying life event. |
Employers who self-fund must offer enrollment when employees become eligible for the benefit and hold at least one annual open enrollment period. |
|
Allowance or premium caps |
The ICHRA has no annual contribution limits. |
The insurer sets the group plan’s premium rate annually. |
There are no preset limits. However, employers must pay all employee medical claims as directed in the plan documents. A high claims year can result in increased stop-loss coverage premiums during the renewal period. |
|
ACA employer mandate |
The ICHRA can satisfy ACA requirements if the employer offers the benefit to at least 95% of their full-time workers and their dependents, and the allowance meets the annual affordability rate. |
Traditional group plans can satisfy ACA requirements if the coverage is affordable and meets MEC and minimum value standards. |
Self-funded group plans can satisfy ACA requirements if the coverage is affordable and meets MEC and minimum value standards. |
|
Flexibility |
Employers can vary eligibility and allowance by class, age (up to 3:1), or family size. They can also determine which expenses are eligible for reimbursement. Depending on the plan design, employees can use their ICHRA funds to pay for individual plan premiums and out-of-pocket expenses. |
Employees are limited to the single group plan selected by the employer. Within the plan, the insurer decides which healthcare services and items it will cover. |
Employers can customize their self-funded plan design. But it comes with greater financial exposure and may still not meet every employee’s medical needs. |
|
Cost control |
Employers set their own allowance amounts. There are no premium hikes or claim risks. |
Premiums often rise annually and require minimum employer contributions. During a high utilization year, employers could face 20-40% premium increases. |
Costs vary monthly depending on employee claims, which can be unpredictable. |
|
Premium tax credits |
Employees can’t participate in the ICHRA and receive premium tax credits. They may opt out if the ICHRA isn’t affordable. If the ICHRA is affordable, they should opt in to the benefit. They must waive their credits. |
Employees are generally ineligible for tax credits unless the plan is unaffordable. |
Employees are generally ineligible for tax credits unless the plan is unaffordable. |
|
Tax benefits |
ICHRA reimbursements are tax-deductible and excluded from payroll taxes for employers. Reimbursements and payments are income-tax-free for employees. With off-exchange plans, the employee’s portion of premiums can be withheld pre-tax. |
Employer-paid premiums are tax-deductible for employers. The employee’s portion of the premium can be withheld pre-tax. |
Medical claim payments are tax-exempt for employers. |
|
Administration |
Easy to manage with ICHRA software, which automates compliance, reimbursements, and employee documentation storage. Full-service ICHRA administration solutions, such as Remodel Health, are ideal for ALEs that require greater support. |
From renewals to plan negotiations to employee communications, traditional group coverage can be time-consuming and complex. |
Employers manage all claims and compliance, which can be an administrative burden. Third-party administrators can help take on some of the essential tasks, but it comes at an added cost. |
What are the steps to launching an ICHRA?
Transitioning to an ICHRA doesn’t have to be complicated. By following the steps below, you’ll be well on your way toward designing, implementing, and managing your ICHRA.
Step 1: Review your current benefits strategy
First, you must determine whether an ICHRA will coordinate with your overall goals. Don’t just look at your budget. Consider other factors such as business size, your staff’s healthcare needs, and long-term strategy. For instance, suppose your company is expanding across multiple states. In that case, an ICHRA is an excellent way to support all your W-2 employees, regardless of their location.
If you’re an ALE switching to an ICHRA from traditional group health insurance, understanding your ACA affordability and reporting requirements is crucial. Remodel Health’s benefits consultants can help you review your current plan and determine whether an ICHRA is a good choice for your company.
Step 2: Contact Remodel Health for a quote
When you’re ready to move forward, Remodel Health will provide a personalized ICHRA analysis and quote. We’ll ask for your employee count, workforce details, and current benefit annual spending. Then, we’ll create a custom proposal comparing your existing coverage with an ICHRA design. This allows you to see if switching to an ICHRA makes sense.
Unlike software-only platforms, we take a hands-on approach to walk you through the process from start to finish. Collaborating with your team to find the right balance of cost savings, compliance, and employee satisfaction is our top priority.
Step 3: Design the benefit with our guidance
With Remodel Health’s specific recommendations, you’ll build an ICHRA that fits your organization’s needs. We’ll help you choose an effective date, define contribution amounts, set up employee classes, and establish eligibility rules. If you’re an ALE, we’ll ensure your benefit is compliant with employer mandate requirements so you avoid any tax penalties.
Our software simplifies compliance documentation while our experts ensure your new benefit is both flexible and sustainable. With assistance from our team, we’ll help you offer a budget-friendly benefit that’s easy to manage.
Step 4: Communicate the change to employees
Clear communication is key to a smooth benefit launch — especially if your employees are transitioning from traditional group coverage. It’s important to explain how an ICHRA works, when the change takes effect, and what actions your staff need to take so they can get the most value out of the benefit.
Remodel Health supports you every step of the way with tailored communication materials, live education sessions, and one-on-one employee assistance. We ensure that every team member understands their ICHRA and has the tools they need to navigate the benefit.
Step 5: Reach out to Remodel Health for employee support in enrolling in individual coverage
To use their ICHRA allowance, employees must enroll in a qualifying individual health insurance plan. While employers can’t recommend specific plans, Remodel Health’s licensed advisors guide employees through the process, helping them compare options, understand coverage levels, and enroll directly through our platform. We even offer in-house Medicare support for eligible employees.
Step 6: Set up payments and payroll integrations
Once your ICHRA launches, Remodel Health handles the most complex parts of administration, from premium payments to claim substantiation. Our payments technology processes off-exchange insurance premiums automatically with 99%+ accuracy, and our dedicated team handles the rest, ensuring there are no pesky coverage gaps.
Employers deposit contributions into a secure account, and our system routes payments directly to carriers. With ADP, Paylocity, and more than 200 other HRIS and payroll integrations, you can manage everything seamlessly and keep your ICHRA compliant and running smoothly throughout the year.
How to administer a compliant ICHRA
Managing an ICHRA requires close attention to IRS, ERISA, and ACA regulations. But the right partnership and administrative tools can make it simple! Remodel Health’s ICHRA+® platform includes built-in compliance features that automatically adapt to new regulations, reducing your administrative workload and ensuring ongoing accuracy.
Get everything you need to know about designing and managing a compliant ICHRA
See our blog post
Implementing ICHRAs allows employers to provide flexible and personalized healthcare benefits to their employees while managing costs effectively. By following the outlined steps and adhering to administrative requirements and best practices, organizations can successfully set up and manage an ICHRA program that meets the unique needs of their workforce.
- Compliance with regulations – Ensure compliance with all applicable laws and regulations governing ICHRAs, such as the ACA and IRS guidelines. Partnering with an experienced ICHRA administrator like Remodel Health can simplify navigating its complex regulatory landscape.
- Documentation and record-keeping – Maintain accurate and detailed records of all ICHRA-related transactions, including reimbursements and employee enrollment information. Documentation should be readily accessible and organized to simplify auditing and reporting requirements.
- Ongoing program management – Regularly review and update the ICHRA program to align with evolving employee needs and regulatory changes. Evaluate the program’s effectiveness, gather employee feedback, and make necessary adjustments to ensure its success.
- Employee support and engagement – Encourage employee engagement by offering regular educational sessions, webinars, or workshops to inform employees about their healthcare options and the benefits of an ICHRA. Provide access to dedicated support channels where they can seek guidance or resolve any issues.
History of the ICHRA
The HRA model of distributing tax-free medical dollars to your staff has been around for a while. Previously, though, strict rules had limited many employers from taking advantage of this innovative model.
HRAs began in 1974 with ERISA, aiming to slow down rising medical costs. By the time the 2000s arrived, the IRS had offered some updates that allowed HRAs to shine. The changes improved flexibility for employers to determine different reimbursement amounts for employees across their organization. Those funds could then be used toward both medical expenses and premiums.
Problems arose when the Affordable Care Act (ACA) brought new definitions and requirements to health insurance plans in 2013. HRAs fell under this new definition of a plan and became subject to the requirement of providing essential health benefits and having no lifetime limits. Thus, the federal government considered HRAs that didn’t integrate with fully insured group plans (like a group coverage HRA, or GCHRA) as noncompliant.
Some early HRA vendors like Zane Benefits, which later became PeopleKeep, a subsidiary of Remodel Health, continued to argue that HRAs for individual health insurance were valuable to employers and employees.
Birth of the QSEHRA and ICHRA
While the ACA improved access to medical coverage through the individual market, its disruption to the industry increased costs for group healthcare even more, especially for small businesses. To give employers an alternative to canceling plans they couldn’t afford, Congress enacted the 21st Century Cures Act. Former President Barack Obama signed the bill into law in December 2016, creating the qualified small employer HRA (QSEHRA). This allowed small employers with fewer than 50 FTEs to offer tax-free contributions to their employees for individual health insurance premiums and qualified out-of-pocket medical expenses.
However, large employers still couldn’t use an HRA for individual health insurance. To appeal to these problems, the Trump administration released new rules in 2019 outlining two new HRAs: the ICHRA and the excepted benefit HRA (EBHRA), both set to begin in 2020. Finally, large organizations could take advantage of the cost control and flexibility that smaller employers had enjoyed since 2016.
Eligible ICHRA expenses
Here's a look at the medical expenses an ICHRA covers.
All ICHRA plans:
- Individual health insurance premiums – ICHRA funds can be used to pay for individual health insurance premiums, including policies purchased through state or federal marketplaces, private exchanges, or insurance carriers. This flexibility allows employees to choose plans that best suit their personal and family needs.
If you design your ICHRA to reimburse employees for qualified medical expenses, it can also cover the following expenses:
- Prescription drugs – Prescription drugs prescribed by a healthcare professional are generally covered under an ICHRA. Individuals can utilize their allocated funds, from essential maintenance medications to acute treatments, to meet their prescription needs.
- Doctor and specialist visits – ICHRA funds can be used to cover the costs of visits to primary care physicians, specialists, and other healthcare providers. This includes routine check-ups, consultations, and necessary medical treatments.
- Hospital and surgical services – Inpatient and outpatient hospital services, surgical procedures, and associated fees are generally eligible expenses under ICHRA. This gives individuals financial support for necessary medical interventions, ensuring they can access quality healthcare when needed.
- Diagnostic tests and laboratory services – From X-rays and MRIs to blood tests and lab work, ICHRA funds can be used for various diagnostic tests and laboratory services. These essential services aid in accurate diagnosis and appropriate treatment planning
- Over-the-counter medications – Due to changes introduced in the CARES Act in 2020, over-the-counter medications are eligible expenses under an ICHRA.
Restrictions and limitations on expenses
While an ICHRA provides significant flexibility, knowing the restrictions and limitations associated with eligible expenses is essential. Here are a few key considerations:
- Alternative treatments and procedures – ICHRA funds may not cover expenses related to alternative treatments, experimental procedures, or services that aren’t considered medically necessary.
- Cosmetic procedures – Cosmetic procedures, such as elective surgeries or treatments performed for aesthetic purposes, are typically not eligible expenses under an ICHRA. However, exceptions may apply in cases where they are deemed medically necessary.
- Non-medical expenses – Expenses unrelated to medical care, such as gym memberships, vitamins and supplements, and general well-being programs, are generally not eligible under an ICHRA unless they are medically necessary and prescribed by a doctor.
ICHRA frequently asked questions (FAQs)
ICHRA FAQs for employers
What are the tax benefits of offering an ICHRA?
ICHRA reimbursements and payments are free from employer payroll taxes and exempt from employee income taxes, lowering tax liabilities for both parties.
Can an ICHRA fulfill ACA requirements for large employers?
Yes, but only if the ICHRA’s allowance meets the IRS’s annual affordability standards. For 2026, coverage is affordable if an employee’s share of the lowest-cost silver Marketplace plan (after applying their ICHRA allowance) doesn’t exceed 9.96% of their household income.
Your employees must have a qualified individual plan that meets MEC and minimum value standards to participate in the ICHRA, which automatically fulfills the other requirements of the employer mandate.
How do I determine the reimbursement amounts for employees?
Begin by reviewing your benefits budget and the average health plan costs in your area, which can vary depending on factors like age, geography, and family size. Considering what other competitors in your industry are offering in terms of health benefits will also help you remain competitive.
ALEs must also ensure their allowances meet ACA affordability rules. You can further tailor allowances by employee class, age, and family status to balance flexibility and cost. Gathering feedback from employees can also help refine allowances during renewal periods.
Visit our blog to learn how to determine the right ICHRA allowances for your employees.
Is there a minimum or maximum contribution limit for ICHRA?
No. There are no federal minimum or maximum limits for ICHRA contributions. Employers can adjust allowance amounts each plan year as needed.
ICHRA FAQs for employees
Are ICHRA contributions considered income
No. ICHRA contributions are completely tax-free for employees, meaning they don’t count as income.
Can I use ICHRA funds for any health expenses?
The ICHRA can reimburse a variety of medical expenses, as defined in IRS Publication 502 and the CARES Act, including health insurance premiums, mental health services, and over-the-counter medications. However, employers can also limit reimbursements to specific expenses, such as premiums only.
With Remodel Health, your employer will provide a monthly contribution for your individual health insurance premiums. That way, you don’t need to request reimbursement for the cost. If your employer added an HRA for eligible expenses, you’ll be able to get reimbursed for eligible expenses.
What happens if the ICHRA plan is unaffordable for me?
If you have an affordable ICHRA allowance, you can’t collect your premium tax credits even if you opt out of the ICHRA benefit. In that case, it’s best to opt into the ICHRA. However, if your ICHRA allowance is unaffordable, you can opt out of the benefit and continue collecting your tax credits.
Do I have to choose a specific health insurance plan?
You don’t need to enroll in a specific insurance plan.. But, you must have a qualifying individual health plan that provides MEC to use the ICHRA. Eligible plans include ACA-compliant Marketplace or private exchange plans, Medicare Parts A and B together, Medicare Advantage, certain student health coverage, and catastrophic policies (for those who qualify).
If you don’t currently have qualifying coverage, you can enroll during the annual Open Enrollment Period or a special enrollment period triggered by your employer’s offer of the ICHRA.
Will my ICHRA affect my tax credits?
Yes. You can’t take advantage of the ICHRA and collect your premium tax credits at the same time. You must choose between the two based on your ICHRA affordability. If your ICHRA allowance is affordable, you’re ineligible for your tax credits. If it’s unaffordable, you can opt out of the ICHRA and claim your subsidy.
Learn more about premium tax credits and how they interact with ICHRAs in our blog.
Ready to offer an ICHRA?
If you’re ready to modernize your benefits strategy, the team at Remodel Health is here to help! Our ICHRA+® administration solution is designed for large and enterprise employers, delivering a quality experience that combines hands-on service, expert consultation, and integrated technology. From setup to ongoing administration, our team helps you transition from group coverage to a flexible, cost-effective health benefit that works for your business.
Contributors:
Elizabeth Walker
Content Marketing Specialist
Sources:
ICHRA resources from our blog

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