ICHRA Class Assignment

Which employees belong in which ICHRA class is a written rule, not a job-title decision.

Permitted classes are defined by employment status, location and a few other categories. Sorting every employee into exactly one class, and writing down the rule, is the first step in any ICHRA design.

Ask Whether an ICHRA Fits

What To Know

What to check when assigning classes.

Full-Time and Part-Time

Pick a written definition of full-time and part-time and apply it the same way to everyone. Counsel should confirm the definition.

Salaried and Hourly

Pay basis is a permitted class. Salaried and hourly employees can receive different allowances if each class is treated consistently.

Job Title Is Not a Class

Titles such as sales, service or office are not permitted classes by themselves. A title only works when it also matches a permitted class.

Seasonal, Union and Waiting-Period Staff

Seasonal employees, union employees and employees still in a waiting period are permitted classes with their own rules.

One Class per Employee

Each employee belongs in exactly one class at a time. Overlaps and gaps are where compliance problems start.

Check the Cost by Class

Once classes are set, model the monthly allowance for each one before you commit.

Step by Step

How to assign ICHRA classes in practice.

The rules give you a short list of permitted classes and one hard requirement: everyone in a class is treated the same. The work is turning your actual workforce into that structure and writing the rule down before the first notice goes out.

The permitted classes

Under the individual coverage HRA rules, an employer can define classes of employees by full-time or part-time status, salaried or hourly pay, seasonal status, coverage under a collective bargaining agreement, a waiting period, work location in a particular rating area, and temporary employment through a staffing firm. Some employers also use non-resident aliens with no U.S.-source income as a class. Classes can be combined, so full-time hourly employees in one rating area can be a class of their own. What you cannot do is invent a class, such as sales or service staff, that is not on the list.

Within a class the allowance has to be offered on the same terms to everyone. The one built-in flexibility is that the allowance can rise with an employee age and with the number of family members covered, within the limits the rules allow. Counsel should review the class definitions, and when a group plan is offered to some classes and an ICHRA to others, minimum class size rules can apply to certain classes.

Six steps to a clean class structure

  1. List every employee with pay basis, scheduled hours, work location, hire date and any union coverage. A current census is the best starting point.
  2. Write the definitions. Decide how many hours separate full-time from part-time, what counts as seasonal, and how long the waiting period is. A waiting period can run up to 90 days.
  3. Match each employee group to the permitted classes. If a group fits two classes, write which one controls so no one is left in a gap or counted twice.
  4. Check the cost of each class. Model the monthly allowance against the number of employees in the class before you commit.
  5. Test affordability for every class. A class that fails is a problem even if the average passes.
  6. Put the rule in the plan document and the employee notice, and apply it the same way every year.

An illustrative example

Take a service business with about forty employees. The table shows how its workforce could map to classes. The groups and rules are illustrative, and the real definitions need counsel review.

Employee group Pay and hours Class Note
Managers and office staff Salaried, full-time Full-time salaried One allowance for the class
Technicians Hourly, full-time Full-time hourly Allowance can differ from the salaried class
Lot and delivery staff Hourly, under the part-time threshold Part-time hourly Threshold must be written down
Summer crew Hired for the season Seasonal Seasonal definition in the plan
Anyone in the first 60 days Any status Waiting period Controls until the waiting period ends

Illustrative only. Job titles such as technician or manager are used here only to describe who sits in each class. They are not classes themselves.

Common mistakes

  • Using job titles as classes, such as giving sales staff a different allowance than service staff without a matching permitted class.
  • Changing definitions from year to year without a reason, which makes treatment look arbitrary.
  • Letting a manager move an individual between classes at discretion instead of by a written rule.
  • Forgetting to say which class controls when an employee fits more than one.
  • Setting classes before testing affordability, then discovering one class fails.

If you want the classes tested against your own census, our fit analysis and the allowance calculator are the next steps, and we can run both for you.

Questions We Get

The questions employers ask about assigning ICHRA classes.

Can I create my own classes?

No. The rules list the permitted classes. An employer picks among them and cannot invent new ones.

Can the allowance differ inside a class?

Within a class the allowance must be the same for everyone, except that it may rise with age or family size within the limits the rules allow.

Can I move an employee between classes?

Yes, when their status actually changes, for example from part-time to full-time. Document the rule and apply it consistently.

Do all permitted classes apply to every employer?

No. Employers pick the classes that match their workforce, and some classes depend on facts such as a union agreement.

Who decides the definition of full-time?

The employer sets a written definition within what the rules allow. Counsel should review it before the first notice.

What if an employee fits two classes?

Each employee needs one governing class. Write the order of precedence into the plan, and have counsel confirm it, before assigning anyone.

Do class rules change by industry?

The permitted classes are the same, but the practical choices differ. Our industry pages show how each workforce is usually sorted.

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.

Sources

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 →

Let’s Get to Work

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What to send

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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