Plain-English updates on CHOICE Arrangements (ICHRA), compliance deadlines, legislation, and the market forces shaping your employer clients' renewals.
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.
Most ICHRA problems come from a short list of avoidable mistakes: late notices, class design errors, affordability shortcuts, weak substantiation, and forgotten filings like PCORI. Here's a checklist to review before your clients' next plan year.
The ICHRA pitch that works for a 12-person firm is the wrong pitch for a 300-employee employer. Here's how to adjust the conversation by employer size, with the 2026 numbers for QSEHRA limits, affordability, penalties, and HSA pairing.
CFOs don't need the regulatory history of ICHRA. They need to know what it costs, how predictable that cost is, what the tax treatment is, and where the risks are. Here's a framework for a finance-first conversation heading into 2026.
Classes are what make ICHRA flexible, and the minimum class size rule is what trips up hybrid designs. Here's how the 2019 rule's 10 classes work, when minimum sizes apply, and what to settle before the October 3 notice deadline for January 1 plans.
For applicable large employers, an ICHRA allowance has to clear the IRS affordability test or the employer risks a penalty. This walkthrough covers the 2025 percentage, the safe harbors, and a worked example you can adapt.
Individual coverage HRAs have been available since 2020, but many employers still haven't heard of them. Here's a refresher on how ICHRA works and why it deserves a place next to fully insured and level-funded quotes this renewal season.