Flowchart: Are My Employees Eligible for ICHRAs?

On June 13, 2019, the Trump administration finalized a new rule that allows employers to start offering health reimbursement arrangements (HRAs) as soon as January 1, 2020, to employees who enroll in individual health coverage. Formerly, most HRAs had to be “integrated” with group coverage to comply with the Affordable Care Act (ACA).

Funds in this new “individual coverage HRA” (ICHRA) will be available to reimburse premiums for individual health insurance, whether offered on or off an ACA exchange, as well as Medicare coverage. But first, the ICHRA must meet various conditions to comply with the new rules.

To help you figure out which employees could be offered an ICHRA, use the flowchart below.