FAQ
Frequently asked questions
For brokers evaluating Choice Arrangement Deck. Don't see your question? Ask us.
What is a CHOICE Arrangement?
A CHOICE Arrangement is the new name for an Individual Coverage HRA (ICHRA). In September 2026, CMS and the SBA began calling ICHRAs “CHOICE Arrangements.” It is an employer-funded health reimbursement arrangement: the employer sets a monthly allowance, employees buy their own individual-market coverage, and the employer reimburses premiums (and, if the employer chooses, other medical expenses) up to the allowance.
Did the rules change when ICHRA became the CHOICE Arrangement?
No. The name changed; the underlying rules did not. You'll see both terms on this site, and the tool works the same way for both.
Who is Choice Arrangement Deck for?
Health insurance brokers, agents, and agencies who advise employers on a CHOICE Arrangement (ICHRA). Employers don't need an account; they receive the proposal you create.
How does the affordability test work?
For each employee, take the monthly premium of the lowest-cost silver plan for self-only coverage where the employee lives, and subtract the employer's monthly allowance. If what's left is no more than the IRS affordability percentage of the employee's household income, the offer is affordable. Because employers don't know household income, IRS safe harbors let them use wages or the federal poverty line instead. See a worked example.
What affordability percentage does the tool use?
9.96% for plan years beginning in 2026 (IRS Rev. Proc. 2025-25) and 10.22% for 2027 (IRS Rev. Proc. 2026-26). The percentage is updated when the IRS publishes the figure for a new year.
Which safe harbors are supported?
The three affordability safe harbors — rate of pay, Form W-2, and federal poverty line — plus the ICHRA location safe harbor, which lets the employer use the lowest-cost silver plan at the employee's primary worksite instead of their home.
Which states are covered?
The states that use the federally facilitated marketplace, HealthCare.gov. States that run their own exchange, such as Minnesota (MNsure), are planned for a later release.
Where do plan and premium figures come from?
From public government data: the CMS Exchange Public Use Files (plans, service areas, and premiums), CMS rating-area definitions, HUD and U.S. Census Bureau geographic files, and IRS and HHS guidance for the affordability percentage and poverty guidelines. See every data source.
How current is the data?
Plan and premium data is refreshed each plan year when CMS publishes it, and again when CMS publishes updates. Each proposal shows the plan year it's based on.
What census information do I need?
For each employee: age (or date of birth), home ZIP code (and county if the ZIP crosses county lines), coverage tier, wage information for the safe harbor you choose, and employee class. Employee names and Social Security numbers are not needed.
How is census data protected?
Census data is encrypted in transit and at rest, deleted automatically after a retention period, and never sold. See the Privacy Policy for details.
Can I put my own branding on proposals?
Yes. Proposals carry your agency's logo, colors, and contact details. You can deliver them as a PDF, an editable PowerPoint file, or a shareable link.
Does this help employers avoid employer mandate penalties?
Applicable large employers (generally 50 or more full-time employees, including full-time equivalents) can owe a penalty if a full-time employee gets a premium tax credit because the coverage offered wasn't affordable. The tool helps you find allowances that meet the affordability test under the safe harbor you choose. Final decisions belong to the employer and its tax and legal advisors.
Is this tax, legal, or insurance advice?
No. Choice Arrangement Deck produces estimates from public data to support your recommendations. It is not tax, legal, or insurance advice, and it doesn't replace the employer's own advisors.
How much does it cost?
See Pricing. Introductory pricing is still being finalized, and early-access brokers will hear about it first.
Where the numbers come from
Affordability and premium figures are built from public government data that anyone can check.
- Plans & premiums: CMS Exchange Public Use Files (Plan Attributes, Rate, and Service Area files) for HealthCare.gov states.
- Rating areas: CMS state geographic rating area definitions.
- ZIP codes & counties: HUD USPS ZIP crosswalk and U.S. Census Bureau geographic files.
- Affordability rules: IRS guidance (9.96% for 2026, 10.22% for 2027) and HHS federal poverty guidelines.
Refreshed each plan year when CMS publishes updates. Figures are estimates from public data, not tax or legal advice.
See all data sourcesStill have questions?
We're happy to walk you through how it works.