Benefit costs often flow into the rates a contractor charges the government, so a benefit change touches the books.
A contractor fringe benefit costs are commonly built into indirect rates. Before switching to an ICHRA, accounting and contracts staff should see how the allowance will appear in those rates.
What accounting should review.
Fringe Pools
Benefit costs often sit in a fringe or indirect pool. Find out where an allowance would land.
Start Date
Choose a start date with accounting. A mid-year change can complicate rate calculations.
Group Plan Costs Today
Compare the allowance to the current group plan cost in the same pool.
Rate Submissions
If rates are submitted or audited, the change needs documentation.
Contract Type
Contract type affects who bears a benefit cost change. Ask contracts staff.
Keep Records
Keep the plan documents and cost model with the rate files.
How an ICHRA Changes a Contractor Fringe Rate
Billing rates carry the cost of your benefits to the government. Moving from a group plan to an ICHRA changes the number inside the fringe pool, and the rates have to be revised and documented.
The cost rule
Under the federal cost principles, fringe benefit costs are allowable when they are reasonable and are required by law, by an employer-employee agreement, or by an established policy of the contractor. An ICHRA that is adopted through a written plan document and communicated to employees fits the established-policy test, and the written record is what supports it. The cost principle names employee insurance among fringe benefits.
Source: FAR 31.205-6(m)(1).
An illustration of the rate effect
Assume 40 employees and an annual labor base of $3,200,000 in the fringe pool. Health cost per employee and the take-up rate move the fringe rate directly.
| Scenario | Annual employer health cost | Health portion of fringe rate | On $60 of direct labor |
|---|---|---|---|
| Group plan at $600 a month for 40 employees | $288,000 | 9.00% | $5.40 |
| ICHRA at $500 a month for all 40 employees | $240,000 | 7.50% | $4.50 |
| ICHRA at $500 a month with 32 of 40 enrolled | $192,000 | 6.00% | $3.60 |
All figures are illustrative. The allowance is only paid to employees who are enrolled in individual coverage and submit proof, so the cost follows enrollment. The same effect applies in reverse if the allowance is set above the group plan cost.
How a change reaches the billing rate
Billing rates are set by the contracting officer or the responsible auditor and should approximate the final indirect cost rates expected for the contractor’s fiscal year. The rates can be revised prospectively or retroactively by mutual agreement to avoid a substantial overpayment or underpayment. The contractor must submit its final indirect cost rate proposal within six months after the end of each fiscal year. The practical effect is that a mid-year switch to an ICHRA should be put in front of the contracting officer when it is adopted, with the cost model, not for the first time in the year-end proposal.
Sources: FAR 42.704 and FAR 52.216-7(d) and (e).
Questions for accounting and contracts staff
- Which pool holds health costs today, and what is the base used to allocate it?
- Do the contracts include fixed-price work that will absorb a rate change, and which are cost-reimbursement?
- Does the unit follow cost accounting standards, and does the switch change how the cost is accumulated or allocated?
- Are forward pricing rates in front of the government that assume the old plan cost?
- Where will the plan document, the board or management approval and the cost model be kept for audit?
Cost accounting and rate-submission questions belong with the contractor’s accountants and contracts counsel.
The questions contractors ask about ICHRAs and billing rates.
Do benefit costs go into billing rates?
Often. Fringe benefit costs are commonly built into indirect rates, but practice varies by contractor.
Who should review the change?
Accounting and contracts staff, before it takes effect.
Does a mid-year start cause problems?
It can complicate rate calculations, so choose the start date with accounting.
Is a fixed allowance easier to forecast?
Yes. A fixed allowance per class is easier to project than a renewal.
Do fixed-price contracts matter?
Contract type affects who bears a cost change, so ask contracts staff.
Do you give accounting advice?
No. We provide the cost model, and your accountants decide the treatment.
Is there a defense contractor page?
Yes. See our ICHRA for defense contractors 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.
Where these details come from.
This page summarizes public guidance reviewed in October 2026. Rules change, so confirm current requirements with counsel.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
More ICHRA questions and the industries they affect.
Federal Contract Benefit Requirements
Service Contract Act health and welfare.
Allowance Cost Modeling
Peak and slow season budgets.
Nonprofits
Design and grant cost rules.
ICHRA for Defense Contractors
Federal contract requirements and billing rates.
ICHRA for Technology Companies
Salaried teams, remote hires and contractors.
ICHRA for Manufacturing
Plants, shifts and bargaining units.
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.
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