Real estate and property management firms mix agents, on-site staff and office teams. An ICHRA lets each employee class have its own allowance.
Under an ICHRA, a real estate or property management company picks the permitted classes it wants, such as salaried office staff, hourly maintenance crews and part-timers, funds each at its own monthly amount, and can scale the amount to the property’s location. The hard parts are deciding who counts as an employee, drawing the class lines and checking affordability.
Why real estate and property management firms look at an ICHRA.
Salaried and Hourly Classes
Property managers on salary and hourly maintenance or leasing employees belong to separate permitted classes. Inside a class, the allowance is the same for all.
Each Property Can Be Its Own Rating Area
Portfolios often span several rating areas. A firm can set an allowance per area, and our calculator prices each address.
Full-Time and Part-Time Classes
Part-time leasing agents and on-site team members can be grouped into a class of their own with a suitable allowance, which beats leaving them out or loading them onto the group plan’s rates.
On-Site Turnover Gets a Known Cost
Turnover among on-site roles is high. Since each class has a set monthly dollar amount, the benefits cost of replacing someone is clear on day one.
A Waiting Period for New Hires
Payment of the allowance can be held off for as long as 90 days after hire, so long as everyone in the same class faces the same wait.
A Different Option from Group Health
An ICHRA need not replace the group plan. It may take its place, or cover only some classes while the group plan continues for others, depending on participation and cost.
The real estate issues that decide whether it works.
Affordability for Larger Firms
Once a firm reaches 50 full-time equivalents, the coverage it offers has to be affordable under federal rules. Test each class rather than relying on a company-wide average.
Agents and Contractor Status
Many licensed agents work as independent contractors and so sit outside the arrangement. Confirm each person’s classification with counsel.
Plan Choice Near Each Property
Individual plans are bought in the employee’s own market, so look at carriers and provider networks close to every property.
Employee Shopping Experience
Maintenance and on-site employees seldom shop for insurance. Someone should guide them through the exchange and through reimbursement.
Notice and Timing
The written notice for eligible employees is due at least 90 days ahead of the plan year, so work backward from your start date.
Variable-Hour On-Site Staff
People on rotating or on-call shifts need a precise classification, because it controls the allowance and what must be reported.
What to settle before moving a firm to an ICHRA.
Which agents and staff are employees?
Make a complete list of agents and staff, then have counsel verify whether each is an employee or a contractor.
Which properties are in which rating area?
Record every property address along with its rating area before you fix any allowance.
Which employees are in which class?
A job title is not a class. Group your people by full-time or part-time and salaried or hourly status.
Who helps employees buy a plan?
Decide who will field employee questions and at which points during the first enrollment.
Does every class pass affordability?
Run affordability for each class separately; one class that fails is a compliance problem.
How are owners and principals treated?
Owners and principals can be taxed differently, so look at them separately with counsel.
See the real estate and property management benefits guide →
The questions real estate and property management firms ask about ICHRAs.
Can a real estate firm give agents an allowance?
No, only employees qualify. Agents who are independent contractors fall outside the arrangement, and counsel should confirm how each is classified.
Can on-site staff and office staff have different allowances?
They can, when the two groups fall into different permitted classes, for example salaried versus hourly or full-time versus part-time. A title does not make a class.
Can a firm set different allowances for each property?
Yes, by putting employees in different rating areas into separate classes. Everyone in a given class gets identical treatment.
Can part-time leasing staff get an allowance?
Yes. Part-timers form a permitted class and may receive an allowance of their own.
Does a new hire have to wait before the allowance starts?
Up to 90 days is permitted, and the same period has to apply to every member of the class.
What notice do employees need?
Written notice has to reach each eligible employee at least 90 days ahead of the plan year, which means counting backward from your start date.
Should a firm keep its group plan?
Both paths are common. A company might retain its group plan for one class and put the rest on an ICHRA, or switch completely. Cost, participation and class design drive the choice, and we run the numbers both ways.
Consider this page a general overview of individual coverage HRAs, not legal or tax counsel. Anything specific to your own plan belongs with your tax advisor and ERISA attorney, and we are happy to involve them.
Where these details come from.
The guidance summarized here is public and was last reviewed in October 2026. Because requirements change, check current rules with counsel.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
More ICHRA guides for other workforces.
ICHRA for Mortgage Lenders
Commissioned loan officers and salaried staff.
ICHRA for Construction and Skilled Trades
Union carve-outs and mobile crews.
ICHRA for Professional Services
Partners, associates and support staff.
ICHRA for Local Service Businesses
Small crews across many trades.
ICHRA for Auto Dealerships
Commission pay and variable hours.
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. →
Cookies on This Site
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.
- Essential: needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics: tell us which pages get read, so we know what is worth writing more of.
- Advertising: set by third parties such as ad and social platforms to measure and target campaigns.