An individual coverage HRA lets a practice set separate allowances for salaried clinicians, hourly support staff and part-time employees, and vary them by office location. The work is in the class design, the treatment of owners and the affordability math.
Salaried and hourly are permitted classes. A practice can offer clinicians one allowance and front-office staff another, as long as everyone in a class is treated the same.
Full-time and part-time are permitted classes, which helps when schedules vary by provider and by day.
Practices with several offices face different individual premiums. Allowances can vary by rating area, based on where the employee works.
A defined allowance gives the practice a predictable cost, even when staffing changes through the year.
An employer can set a waiting period of up to 90 days, which can match an introductory period for new staff.
An ICHRA is not right for every practice. We compare it with the group plan side by side.
Owners, partners and some shareholders may be treated differently from employees for benefit purposes. Ask counsel and your tax advisor how they fit before designing classes.
Practices with 50 or more full-time equivalent employees must offer an affordable allowance. Test each class.
A practice under 50 employees is not subject to the ACA employer mandate and can also look at a QSEHRA. We compare the options.
Staff 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, so planning has to start well before the renewal date.
Plan data and employee health information are subject to privacy rules. Review how enrollment data is handled with counsel.
Confirm their status with counsel before drawing class lines.
Write the definitions down and test them against the roster.
Model each location, not one average.
Plan enrollment support before the notice goes out.
If you have 50 or more full-time equivalents, test each class.
Compare the two before you decide.
Yes, if they fall into permitted classes such as salaried and hourly, and everyone in a class is treated the same. Counsel should review the definitions.
Owners, partners and some shareholders may be treated differently from employees. Ask counsel and your tax advisor before designing classes.
Allowances can vary by rating area within a class, based on where the employee works. The rule should be written and applied consistently.
It can. The ACA employer mandate does not apply under 50 full-time equivalents, and a QSEHRA may also be an option. We compare them.
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.
General information about individual coverage HRAs, not legal or tax advice. Plan-specific questions belong with ERISA counsel and your tax advisor, and we will bring them in.
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 →
Field staff and variable schedules.
Teachers, aides and school-year schedules.
Partners, associates and support staff.
Salaried teams, remote hires and contractors.
Small crews across many trades.
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.
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