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.

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How to offer ICHRA alongside other employee benefit programs

Pairing a CHOICE Arrangement with direct primary care

ICHRA is now the CHOICE Arrangement: What you need to know

Earning Accolades in Health Innovation

Remodel Health
601 S. Meridian St.
Indianapolis, IN 46225

Interested in learning more?

Expert insights at your fingertips.

How to offer ICHRA alongside other employee benefit programs

Pairing a CHOICE Arrangement with direct primary care

ICHRA is now the CHOICE Arrangement: What you need to know

Earning Accolades in Health Innovation

Remodel Health601 S. Meridian St.Indianapolis, IN 46225

Remodel Health
601 S. Meridian St.
Indianapolis, IN 46225