Guide
How does an ICHRA work?
An ICHRA works on one simple idea: instead of buying a group plan, the employer gives employees a tax-free monthly allowance to buy their own individual health insurance, then reimburses them. This guide walks through the full flow — start to finish — including what the employer controls, what employees choose, what makes it tax-free, and what happens to unused funds.
By Joe Rosenblatt · Founder & ICHRA Broker, The ICHRA Broker
Key facts
- Step 1
- Employer sets a monthly allowance
- Step 2
- Employees buy individual coverage
- Step 3
- Employees submit proof
- Step 4
- Employer reimburses tax-free
The basic flow
The employer decides a monthly reimbursement amount (the allowance), which can vary by employee class and family size. Employees use it to buy an individual plan on or off the ACA marketplace. They submit proof of coverage, and the employer reimburses them tax-free — usually through payroll or an administration platform. That''s the whole model: the employer funds, the employee chooses, and the reimbursement flows tax-free.
Step by step
- The employer sets the allowance (per class, scaled by age and family size).
- Employees buy a qualifying individual plan or use Medicare.
- Employees submit proof of coverage and, for expense reimbursement, proof of expenses.
- The employer reimburses up to the allowance, tax-free, through payroll.
- Coverage is re-verified each plan year.
Where the money goes
Reimbursements can cover individual insurance premiums and, if the plan is designed that way, other qualified medical expenses (copays, deductibles, prescriptions, dental, vision). The employer defines the scope in the plan document. A premium-only design keeps the money focused on coverage and preserves HSA eligibility; a broader design covers more out-of-pocket costs.
What the employer controls vs. the employee
- Employer controls: the budget (allowance), which classes are eligible, what''s reimbursable, and when the plan year starts.
- Employee controls: which individual plan and network they choose, and their own enrollment.
What makes it tax-free
Because the arrangement is documented, employees attest to qualifying coverage, and reimbursements are substantiated, the money is free of income tax for employees and payroll tax for the employer — and deductible for the business. This compliance layer is exactly what separates an ICHRA from simply handing employees cash, which would be taxable wages.
Timing and unused funds
Reimbursements are typically processed monthly. Because you only pay against substantiated expenses up to the allowance, unused amounts generally aren''t paid out — so your real cost can land at or below budget. The funds belong to the employer until reimbursed; employees don''t take a balance with them.
The employee experience
From the employee''s side: they choose a plan that fits their family (ideally with a broker''s help), submit proof once, and then see tax-free reimbursements arrive through payroll each month. After the initial setup, it runs quietly in the background. Good enrollment support is what makes the experience smooth.
Setting up an ICHRA (the employer side)
Behind the simple employee experience, the employer sets a few things up once: choose which employee classes are offered the ICHRA, set the monthly allowance for each, adopt a written plan document, and send the required employee notice. After that, the month-to-month runs on reimbursements and proof.
Substantiation: how proof works
Before reimbursing, you confirm two things: that the employee is enrolled in qualifying individual coverage, and that the expense (usually the premium) was actually incurred. Employees submit that proof, you verify it, and you keep the records. This substantiation is what keeps the reimbursements tax-free.
What happens when an employee leaves
Because the health plan belongs to the employee, they keep their coverage when they leave — it is their own individual policy, not tied to your business. Their ICHRA reimbursements simply stop as of their eligibility end date, with no plan to unwind.
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The employer sets a tax-free monthly allowance, employees buy their own individual health insurance, submit proof, and the employer reimburses them — no group plan required.
Joe Rosenblatt — Founder & ICHRA Broker, The ICHRA Broker
Joe Rosenblatt is the founder of The ICHRA Broker, an independent ICHRA brokerage that helps small businesses offer tax-free health benefits without a group plan. He works directly with employers and their advisors on ICHRA and QSEHRA setup, plan design, and compliance.
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