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.

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Health Benefits

What is the CHOICE Arrangement?

Sep 3, 2026, 5:10:00 PM 9 min read

ICHRA

ICHRA software vs. full-service ICHRA administration

Aug 27, 2026, 12:42:54 PM 9 min read

Individual Health Insurance

What is Open Enrollment?

Aug 21, 2026, 9:00:00 AM 9 min read

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Interested in learning more?

Expert insights at your fingertips.

What is the CHOICE Arrangement?

ICHRA software vs. full-service ICHRA administration

What is Open Enrollment?

Earning Accolades in Health Innovation

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

Interested in learning more?

Expert insights at your fingertips.

What is the CHOICE Arrangement?

ICHRA software vs. full-service ICHRA administration

What is Open Enrollment?

Earning Accolades in Health Innovation

Remodel Health601 S. Meridian St.Indianapolis, IN 46225

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