DillinghamBenefits
Living Field Note
Field Notes

What Is ICHRA?
(No, Really)

A plain-language walkthrough of how ICHRA works, what your employees actually see, and where it makes sense.

Start with the simple version.

ICHRA stands for Individual Coverage Health Reimbursement Arrangement. That's a mouthful, so let's think of it this way:

Instead of the company buying one big group health plan, you give each employee tax-free money to go buy their own insurance — kind of like a gift card for health insurance.

That's it. That's the whole thing.

How the money actually moves.

Here's what changes when you switch to ICHRA:

The employer money stays the same. The *way* it gets to health insurance changes.

What does the employee actually see?

Let's walk through a real scenario. Meet Sarah, a 35-year-old who works for your company.

The old way (traditional group insurance):

Sarah's paycheck

The company offers a health plan. Sarah picks it. A small amount comes out of her paycheck every month (her premium contribution). The rest of the bill is paid by the company. Done.

Sarah's costs: ~$150/month out of paycheck, plus copays when she goes to the doctor.

The ICHRA way:

Sarah gets a stipend

The company gives Sarah $250/month in ICHRA money (tax-free). Sarah uses that money to buy her own insurance on the open market (or the ACA marketplace). If the insurance costs more than $250, she pays the difference from her own pocket. If it costs less, she keeps the savings.

Sarah's costs: If insurance costs $350/month, she pays $100 out of pocket. If it costs $200, she pays $0 — and saves the $50.

Same employer spend. Different path from employer to insurance.

Try it yourself.

Move the slider. You're setting the monthly stipend — watch who pays what for three different plans Sarah might pick. (Illustrative numbers.)

$250

Gold is the company's stipend. Gray is what Sarah pays out of pocket for each plan.

So why would you even consider it?

Three honest reasons:

1. Choice

Sarah can now pick insurance that fits *her* life, not the plan that fits the largest middle. If she wants a low-deductible plan with her doctor in-network, she can do that. If she wants a high-deductible plan paired with a health savings account, she can do that too. She's not locked into what the company chose for everyone.

2. Simplicity for the company

You're no longer shopping for group plans, negotiating rates, managing renewals, or picking which drugs the plan covers. You pick a monthly stipend per employee. Done. Your HR person gets their Tuesday mornings back.

3. Predictability

A traditional group plan's costs jump around. Last year your renewal came in at +8%. This year it might be +12% or +3%. With ICHRA, you know exactly what you're spending each month. That number doesn't change unless you change it.

Illustrative numbers. The point: one line jumps because the market decides. The other moves only when you decide.

Key point: You're not saving money by switching to ICHRA. You're spending roughly the same amount, but in a different way. The wins are *choice*, *simplicity*, and *budget certainty* — not lower costs.

What could go wrong?

ICHRA is not magic. It has real limitations, and you need to know them upfront.

Geographic problem

ICHRA works great if your employees live in areas with lots of insurance options on the open market. If half your team works in rural Montana, the insurance choices might be thin. One option instead of five changes the calculus.

Illustrative pattern. The check for your company uses the actual carrier count in each employee's zip code.

Low-wage employee problem

If you offer ICHRA stipends, the IRS makes sure employees don't trigger a subsidy from the government (the ACA subsidy). This gets technical fast, but the practical issue: if a stipend is too high relative to an employee's wages, it can accidentally disqualify them from subsidies they might otherwise get. Then the plan doesn't work.

This math is real. It's why ICHRA audits fail — often silently.

Compliance headache

You have to document *everything*. Who got what stipend, why that amount, whether any employee hit a subsidy cliff. The IRS cares. A lot. If you mess this up, the company can face six-figure penalties.

Employee confusion

Sarah now has to go buy insurance herself. That's not as hard as it sounds (the ACA marketplace walks people through it), but you will get questions. "Why is my insurance $400 now?" "Why does my new insurance have different doctors?" "Why did my stipend not cover the plan I wanted?" Be ready to explain.

What does it take to find out?

Here's the part most people overcomplicate. Checking whether ICHRA fits a company is not a six-month project. It comes down to four questions:

1. Where do your people live?

Every zip code has its own menu of individual insurance plans. Some zip codes have five carriers competing. Some have one. The check starts with a map of your employees.

2. What do individual plans cost there?

Pull the actual prices in each of those zip codes, for each employee's age. Not estimates — the real numbers. This tells you what stipend it would take to make the math work.

3. What do your people earn?

This is the subsidy question from earlier. Wages and stipend amounts have to be looked at together, employee by employee, so nobody gets accidentally hurt by the switch.

4. How would you group people?

ICHRA lets you set different stipend amounts for different groups — full-time vs. part-time, one location vs. another. The rules for grouping are strict, so the groups have to be designed on purpose, not by accident.

What information does that take?

Two things, and you already have both:

That's the whole input. From there, the math either works or it doesn't — and it shows you which one before anybody changes anything.

So is it right for you?

ICHRA works best if:

It does NOT work if your workforce is mostly low-wage, you're in a rural area with one insurance carrier, or you can't handle the compliance detail.

The question isn't "Is ICHRA cheaper?" (It usually isn't.) The question is "Does ICHRA fit our structure?" If it does, the wins are real: choice for employees, simplicity for you, and a locked-down budget.

Bottom line: ICHRA is not a cost-cutting move. It's a structural choice. Pick it if the structure fits your company. Skip it if it doesn't.

If this raised the bigger question — what are all the ways a company can buy healthcare? — I keep an interactive walkthrough of the five funding paths, with your own numbers plugged in, at The Five Ways to Buy. No forms, no pitch — just the map, and you can wander it on your own time.

Note on timing: ICHRA rules can change. This walkthrough is current as of August 2026. If you're considering this move, check with someone who stays on top of IRS updates — the details matter.