A software company using an ICHRA gives each employee a monthly allowance and lets them shop for an individual plan in their home state, so nobody has to negotiate a separate group plan for every location. The work is in class design, allowances by rating area, and a notice process that keeps pace with hiring.
A single group plan can be hard to fit to employees in many states. With an ICHRA, each employee buys an individual plan where they live, and the employer sets the allowance.
Allowances can vary by rating area, so an employee in a costly market is not priced like one in a cheap market. Rules must be written and applied the same way to everyone in a class.
New hires in a new state do not require a new group plan. They get the allowance and shop in their own market.
Engineers and support staff can receive different allowances when they fall into separate salaried and hourly classes, as long as the class definitions are clear.
An employer can set a waiting period of up to 90 days, which matters when hiring is fast.
An ICHRA is not right for every technology company. We compare it with the group plan side by side.
Growth to 50 or more full-time equivalents brings the federal requirement that the allowance be affordable. Check each class, and each rating area within it.
An ICHRA covers employees. Contractors and other non-employees need to be classified correctly, and counsel should review the classification.
Individual market options differ by state and county. Check carriers and networks where your employees live.
Employees who are used to a group plan may need help comparing individual plans. Enrollment support affects take-up.
Employees need an ICHRA notice at least 90 days before the plan year, and new hires generally need it by the date they become eligible. Set a process.
State rules can differ for employers with employees in several states. Counsel should review before launch.
Rating areas follow the employee, so keep the roster current.
Confirm classification before building classes.
Model headcount growth by state, not the current roster.
Plan enrollment support before the notice goes out.
Past the 50 full-time equivalent mark, check every class for affordability.
Compare the two before you decide.
Yes. Each employee buys an individual plan where they live, and the allowance can vary by rating area. Counsel should review multi-state compliance.
Within a class the allowance may differ by rating area, tied to where the employee lives. Put the rule in writing and apply it consistently.
Salaried and hourly status are both permitted classes. Define them clearly and apply them to every employee who fits.
No. It is for employees. Contractors and other non-employees should be classified correctly with counsel.
It can, but the allowance has to meet the ACA affordability test for the year, so model each class. The 2027 affordability percentage is 10.22%.
Employees must receive an ICHRA notice at least 90 days before the plan year starts, and they need time to shop. Plan well ahead.
Employees receive the ICHRA notice, and other compliance notices may still apply. See our employee notices page.
Nothing here is legal or tax advice; it is a plain overview of how these arrangements work. Where a decision depends on your own situation, we bring your tax advisor and ERISA counsel into the discussion.
This page summarizes public guidance reviewed in October 2026. Rules change, so confirm current requirements with counsel. Federal agencies now also call ICHRAs CHOICE Arrangements; the rules are unchanged.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
Partners, associates and support staff.
Federal contract requirements and billing rates.
Commissioned loan officers and salaried staff.
Agents, managers and on-site staff.
Clinical staff, owners and associates.
Compare all seventeen workforces side by side.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program: cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.