Staffing agencies carry a workforce that changes by assignment. An ICHRA can give temporary and internal staff separate, predictable coverage.
With an ICHRA, a staffing firm can fund its recruiters and managers at one level and its placed workers at another, then handle assignment turnover through clearly written classes. The real work lies in class design, the ACA measurement rules for hours and the affordability testing.
Why staffing agencies look at an ICHRA.
Internal Staff and Placed Workers
Because individual coverage is owned by the employee, it does not hinge on which client site a worker is assigned to. Recruiters and managers can sit in one class and placed workers in another, each with an allowance that fits.
Coverage That Moves with the Worker
Individual coverage belongs to the employee, so it does not depend on which client site they are assigned to.
Predictable Cost per Head
The agency knows what each covered worker costs per month, even while assignments begin and end around them.
Waiting Periods for New Placements
A wait of up to 90 days is allowed for new hires, a good match for short placements that start and stop quickly.
Rating Areas Follow the Worker
Where an employee lives sets the rating area, and the allowance can follow it, so staff in different markets are treated fairly on price.
A Different Option from Group Health
Not every agency is a fit for an ICHRA. We set it beside the group plan and compare the two.
The staffing issues that decide whether it works.
Affordability Is the Big Test
At 50 or more full-time equivalents, an agency has to offer full-time workers an affordable allowance, and temporary placements are counted too. Every class needs testing.
Measuring Full-Time Status
Assignment gaps affect how hours are measured under the ACA. Choose the look-back method with counsel.
Defining Temporary Workers
Staffing-firm temporary employees can be a class only if the definition is clear. Counsel should review it.
Client Site Differences
Clients may have their own benefit expectations or contract terms. Check the staffing agreements before you change anything.
Notice and Timing
Assignment gaps change how hours are counted for the ACA. Settle the look-back method with counsel.
Employee Support
Placed workers may be buying individual coverage for the first time, so plan enrollment help.
What to settle before moving workers to an ICHRA.
Who is internal and who is placed?
Write the class definitions in plain language, then check them against the actual roster of internal and placed workers.
How do we measure hours across gaps?
Pick the ACA measurement method with counsel before the plan year.
What does the allowance cost at peak?
Model peak and slow placement volume, not one average.
Do client contracts say anything about benefits?
Review them before changing the plan.
Does every class pass affordability?
Check each class for affordability if you reach 50 full-time equivalents.
Who helps workers buy a plan?
Arrange enrollment support in advance of the notice.
The questions staffing agencies ask about ICHRAs.
Can an agency offer different allowances to internal staff and placed workers?
Yes. When recruiters and placed workers fall into permitted classes such as salaried and hourly, each can receive a different amount, so long as each class is handled uniformly. Counsel should read the definitions.
Is there a class for temporary employees?
Staffing-firm temporary employees are a permitted class under the ICHRA rules, but the definition must be clear and consistently applied.
Does an ICHRA work with high turnover?
Often yes, since coverage follows the person rather than the assignment. New hires can be asked to wait up to 90 days, and counsel can confirm the details.
Does an agency with 50 or more employees have to offer affordable coverage?
Yes. Applicable large employers owe affordable coverage to their full-time people, and the allowance has to pass the federal test. The 2027 percentage for affordability is 10.22%.
How do assignment gaps affect full-time status?
They can change who counts as full-time under the ACA measurement rules. Choose your method with counsel before the plan year.
How early do we need to start?
The ICHRA notice has to reach employees 90 days or more ahead of the plan year, so start early.
What notices do we still send?
Employees get the ICHRA notice, but other compliance notices could still apply. Our employee notices page has the list.
This page offers general background on individual coverage HRAs and is not legal or tax guidance. For anything specific to your plan, your tax advisor and ERISA counsel are the right people, and we can bring them in.
Where these details come from.
We summarized public guidance that was reviewed in October 2026. Because requirements change, confirm what applies today with counsel. Federal agencies have also begun to call the arrangement a CHOICE Arrangements; the rules are unchanged.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
More ICHRA guides for other workforces.
ICHRA for Professional Services
Partners, associates and support staff.
ICHRA for Restaurants and Hospitality
Tipped, hourly and seasonal staff.
ICHRA for Construction and Skilled Trades
Union carve-outs and mobile crews.
ICHRA for Trucking and Logistics
Drivers, owner-operators and dispatch.
ICHRA for Home Health and Social Services
Field staff and variable schedules.
ICHRA by Industry
Compare all seventeen workforces side by side.
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