ICHRA
The individual coverage HRA: any size, no federal cap, classes of employees, and why it counts as an offer of coverage.
An individual coverage HRA reimburses premiums and medical costs for employees who buy individual health insurance. Employers of all sizes may offer one, and contribute as little or as much as they want — but on the same terms to everyone in a class of employees, with amounts allowed to rise with age and family size.
Classes are the design tool: full-time and part-time, salaried and hourly, employees in the same rating area or state, seasonal and temporary staff, and others the rule lists. Where the group plan and the ICHRA are split by some of those classes, a minimum class size applies. An employer can offer an ICHRA to one class and the group plan to another, but never both to the same class. Employees must generally have notice 90 days before the plan year.
Where this lesson's rules come from
The sources behind this lesson's requirements, by kind. Background reading explains; it is never the authority for a rule. Anything marked as a convention is ours, not the rule-maker's.
- IRS guidance
- Instructions for Forms 1094-C and 1095-C (2025) (opens in a new tab)Who files 1094-C and 1095-C, when, and the alternative manner of furnishingPDF · Free to read
- Federal agency guidance
- DOL, HHS & Treasury — FAQs on New Health Coverage Options for Employers and Employees, Q5, Q6, Q10 (opens in a new tab)Individual coverage HRAsPDF · Free to read
- Background reading — not an authority
- Wikipedia, “Health reimbursement account” (opens in a new tab)Health reimbursement accountFree to read
The words this page teaches
Each links to its glossary definition, which also names the authority behind it and the components that render it.
- Individual coverage HRAAn HRA, open to employers of any size, that reimburses individual health insurance premiums and costs with no federal dollar cap, offered on the same terms within each class of employees — and never to a class that is offered the group plan
- Applicable large employerAn employer that averaged at least 50 full-time employees, full-time equivalents included, over the prior calendar year — the employers the ACA's employer mandate and Form 1095-C reporting apply to. Companies under common control are counted together