Law, accounting and consulting firms mix partners, professionals and support staff. An ICHRA can give each group its own allowance.
Under an ICHRA, a law, accounting or consulting firm decides which permitted classes it has, such as salaried, hourly or part-time, and funds each at its own level while staff pick coverage wherever they live. Most of the effort goes into defining classes, deciding how partners are handled, and checking affordability.
Why professional firms look at an ICHRA.
Professionals and Support Staff
Salaried and hourly status each qualify as permitted classes, so professionals can receive one allowance and support staff another. The only requirement is equal treatment inside each class.
Hybrid and Remote Employees
Remote and hybrid staff may live in different counties or states, and each buys an individual plan in their home market. Allowances can be adjusted for rating area.
A Known Cost per Employee
Because the allowance is a fixed dollar figure, the firm can forecast benefit spending even when headcount moves up or down with client demand.
Seasonal Staff Can Be a Class
Busy seasons for tax and audit work bring in temporary hires. Seasonal workers form a permitted class and can have an allowance of their own.
A Waiting Period for New Hires
Waiting periods can run to 90 days, which lines up neatly with a probationary stretch for new associates.
A Different Option from Group Health
Not every firm should adopt an ICHRA. We lay it next to the group plan and compare the two line by line.
The professional services issues that decide whether it works.
Partners and Owners
Partners, members and some shareholders may not be treated like ordinary employees where benefits are concerned, so bring in counsel and your tax advisor before you set up the classes.
Affordability for Larger Employers
Once a firm reaches 50 full-time equivalents, the allowance must be affordable under federal rules. Test every class separately.
Smaller Firms Have Options
If the firm has fewer than 50 employees, the ACA employer mandate does not reach it, and a QSEHRA may be worth weighing as well. We set the choices side by side.
Class Size Rules
If a firm keeps a group plan and also offers an ICHRA, minimum class size rules may come into play. Have counsel review this prior to finalizing classes.
Notice and Timing
The ICHRA notice must reach employees at least 90 days ahead of the plan year, so the project has to begin long before the renewal date.
Employee Shopping Experience
People accustomed to a group plan often need guidance in comparing individual plans, and the quality of enrollment help influences how many accept.
What to settle before moving a firm to an ICHRA.
How are partners covered today?
Get counsel to confirm their status before class lines are drawn.
Which roles belong in which class?
Put the class definitions in writing and then test them against the actual roster.
Where does each employee live?
The rating area travels with the employee, so the roster needs to stay current.
Who helps employees buy a plan?
Arrange enrollment support ahead of the notice date.
Does every class pass affordability?
At 50 or more full-time equivalents, every class needs its own affordability check.
Is the group plan still the better answer?
Weigh the two options against each other before you commit.
The questions professional services firms ask about ICHRAs.
Can a firm offer different allowances to professionals and support staff?
Yes. Salaried and hourly are permitted classes, so the firm can pay each a different amount, provided each class is treated uniformly. Have counsel read the definitions.
How are partners treated?
They can be treated differently from rank-and-file staff, so check with counsel and your tax advisor ahead of designing the classes.
Can the allowance vary by location?
Within a class the amount can differ by rating area, depending on where the employee lives or works. Write the rule down and apply it the same way every time.
Does an ICHRA work for a firm with fewer than 50 employees?
It can. The ACA employer mandate applies only from 50 full-time equivalents upward, and a QSEHRA could be another route. We put the choices next to each other.
Does an ICHRA work for a firm with 50 or more employees?
It can. Above that size the firm’s allowance has to clear federal affordability standards for the plan year, so each class gets modeled individually. The 2027 percentage is 10.22%.
How early do we need to start?
Notice must reach employees three months or so before the plan year, to be exact at least 90 days ahead, and shoppers need time as well. Start the project early.
What notices do we still send?
The ICHRA notice goes to employees, and other compliance notices might still apply. Our employee notices page covers them.
Treat this page as general background on individual coverage HRAs, not legal or tax guidance. For questions about your own plan, turn to your tax advisor and ERISA counsel; we are glad to bring them into the discussion.
Where these details come from.
These notes condense public guidance we reviewed in October 2026. Requirements shift, so verify the current rules with counsel. Federal agencies have also begun using the label CHOICE Arrangements for the same arrangement, with no change to the rules.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
More ICHRA guides for other workforces.
ICHRA for Technology Companies
Salaried teams, remote hires and contractors.
ICHRA for Mortgage Lenders
Commissioned loan officers and salaried staff.
ICHRA for Real Estate and Property Management
Agents, managers and on-site staff.
ICHRA for Medical and Dental Practices
Clinical staff, owners and associates.
ICHRA for Staffing Agencies
Internal staff and placed employees.
ICHRA by Industry
Compare all seventeen workforces side by side.
Send us your renewal.
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. →