Can You Offer ICHRA and a Group Plan Together?

The rule: different classes

You can offer a group health plan to one class of employees and an ICHRA to a different class — but you can''t offer the same class both. Classes are defined categories like full-time, part-time, seasonal, or by geographic area.

The guardrail: minimum class sizes

To prevent employers from steering high-cost employees off the group plan and onto the individual market, minimum class-size rules apply when you split a group plan and an ICHRA across classes. The minimum depends on your total employee count.

A typical use case

Keep the existing group plan for full-time staff while offering an ICHRA to part-time or seasonal workers who weren''t eligible before — extending benefits without expanding the group plan. It''s a way to tailor benefits to different parts of your workforce.

Design it with a broker

Because the class and minimum-size rules get technical, this is a setup to design with a broker. Done right, combining an ICHRA with a group plan lets you serve different employee groups while staying compliant.

Why you can't offer both to the same people

The rules prevent offering the same employees a choice between a group plan and an ICHRA, because that would let healthier people pick one and sicker people the other, driving up group premiums. To offer both, you split your workforce into distinct classes and give each class one option — not a choice between the two.

Minimum class size thresholds

When you use an ICHRA for some employees and a group plan for others, a minimum class size applies to prevent gaming. The threshold scales with employer size.

• Fewer than 100 employees: at least 10 in the class.
• 100 to 200 employees: at least 10 percent of total employees.
• More than 200 employees: at least 20 in the class.

A realistic split example

A common design: full-time employees keep the group plan, while part-time or seasonal workers get an ICHRA. Each group is a defined class, each gets one option, and the minimum class size is satisfied. A broker helps you draw the class lines correctly.