ICHRA Has a New Name: Meet the CHOICE Arrangement

On September 3, CMS and the SBA announced that individual coverage HRAs will now be called CHOICE Arrangements. The rules haven't changed. Here's what was announced, what it means for your clients, and how to talk about the new name.

4 min read By Choice Arrangement Deck Team

The individual coverage health reimbursement arrangement has a new name. On September 3, 2026, CMS Administrator Dr. Mehmet Oz and SBA Administrator Kelly Loeffler announced at Hancock Health's Hancock Wellness Center in New Palestine, Indiana, that ICHRAs will now be called CHOICE Arrangements.

If you've spent years explaining "ick-ra" to employers, this is welcome news. Here's what changed, what didn't, and how to use the new name with clients.

What was announced

According to accounts from the event, including Remodel Health (which helped host it) and the local Daily Reporter, the announcement followed a roundtable with Indiana employers, small-business advocates, and insurance market representatives. Officials framed the arrangement as a way for employers, especially small businesses facing rising group premiums, to give employees tax-free money to buy their own coverage.

CMS also launched an employer guide, "CHOICE Arrangements: A Guide for Employers," at cms.gov/choicearrangements. According to Remodel Health's account, CMS's suggested steps for employers were to learn the basic structure, estimate costs and fit for their workforce, connect with a broker or third-party administrator, and visit the new page, which includes:

  • An overview of how CHOICE Arrangements work
  • A cost and contribution calculator
  • A list of CHOICE Arrangement vendors (third-party administrators)

Notice that brokers are named in CMS's own getting-started steps.

What didn't change: the rules

This is a rename, not a new regulation. Remodel Health's summary of the event put it plainly: the same final rules that applied to ICHRA still apply to the CHOICE Arrangement. In practice:

  • Classes, minimum class sizes, and same-terms requirements are unchanged.
  • The 90-day notice still applies (for January 1, 2027 plan years, that means early October).
  • Affordability for applicable large employers is still tested the same way, using 10.22% for plan years beginning in 2027.
  • Substantiation, PCORI, and Form 1095-C reporting work the same way.
  • QSEHRA is a separate, statutory arrangement and isn't affected.

How this differs from the congressional "CHOICE" bills

You may remember that the House passed bills in 2025 that would have written ICHRA into law as the "custom health option and individual care expense arrangement," or CHOICE arrangement: first in the reconciliation bill (those provisions were dropped from the final law), then in H.R. 6703 in December 2025. Those bills would have changed the rules, including a 60-day notice and pre-tax payment of Exchange premiums through a cafeteria plan.

The September announcement doesn't enact any of that. H.R. 6703 has passed the House but not the Senate. Until Congress acts, the CHOICE Arrangement operates under the existing ICHRA regulations.

Why the timing matters

The rename arrives as adoption accelerates. The HRA Council's Volume 5 report, released August 12 and based on data from 17 member organizations, found:

  • More than 20,000 U.S. businesses offer an ICHRA or QSEHRA in 2026, covering at least 500,000 employees.
  • Applicable large employers are the fastest-growing segment, with ICHRA adoption more than doubling on average from the prior year.
  • More than half of enrollments are by employees under age 45.
  • More than two-thirds of small businesses offering ICHRA previously offered no health coverage, and nearly a third of small employers that adopted ICHRA moved from the small group market.

A clearer name, federal promotion, and an official CMS resource page should make first conversations easier, especially with small employers who've never heard of ICHRA.

How to talk about it with clients

  1. Lead with the new name, and bridge to the old one. "A CHOICE Arrangement, previously called an ICHRA" keeps everyone on the same page, since documents, vendors, and IRS forms will use "ICHRA" for some time.
  2. Reassure existing clients. Nothing in their current arrangement needs to change because of the rename. Remodel Health noted that CMS hadn't announced any compliance deadlines for updating plan documents.
  3. Use the CMS page as a neutral resource. Sending a prospect to a government page can lend credibility to a concept that may feel new.
  4. Don't overpromise. The rename doesn't come with a tax credit or new flexibility. Those would require legislation.
  5. Watch for guidance. If agencies update forms, model notices, or regulations to reflect the new name, we'll cover it.

Getting ready for January 2027

With notices for January 1 plan years due in early October, now is the time to finalize classes and allowances. Choice Arrangement Deck can help you turn a census into an affordability analysis and a branded CHOICE Arrangement proposal, so you can bring the new name, and the numbers behind it, to your next client meeting.

The name is new. The opportunity, helping employers offer a benefit their employees can actually use, is the same one brokers have had since 2020, and it may be easier to explain now.

This article is general information for insurance professionals and reflects the rules, figures, and events known as of . It is not legal, tax, or insurance advice. Laws and guidance change, so confirm current requirements with the primary sources and the employer's own legal and tax advisors before acting.

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