Why do I see both ICHRA and CHOICE arrangement?
CMS and HealthCare.gov now call the Individual Coverage Health Reimbursement Arrangement (ICHRA) a CHOICE arrangement. They still note the old name, formerly known as ICHRA, so you will see both names. This guide uses CHOICE arrangement (ICHRA) so you can match it to what an insurer or payroll company calls it.
How do the three options compare?
A group plan is a plan you pick for your team. The other two are defined contribution benefits: you set a dollar amount and each employee buys their own plan. The table uses HealthCare.gov's comparison with 2026 limits.
| Small group plan (SHOP) | CHOICE arrangement (ICHRA) | QSEHRA | |
|---|---|---|---|
| Who can offer it | Generally employers with 1 to 50 employees | Employers of any size with at least one employee other than the owners and their spouses | Generally employers with fewer than 50 full time employees that offer no group plan |
| How the money works | You offer a plan or a choice of plans and pay part of the premium | You set an amount for employees and their dependents if you choose, with no yearly limit | You set an amount up to $6,450 for one person or $13,100 for a household in 2026 |
| What employees need | Nothing extra. They enroll in what you offer | Their own individual health insurance, such as a Marketplace plan | Their own qualifying health coverage, such as a Marketplace plan |
| Small Business Health Care Tax Credit | Possible if you meet the rules | Generally not available | Generally not available |
Employers can offer a CHOICE arrangement or a QSEHRA at any time of year. New employees and employees getting a new offer have a special enrollment period to buy individual coverage.
How does a CHOICE arrangement work?
You give employees a set amount to spend on individual health insurance, and the reimbursement is not taxed to the employee. Employees own the plan they pick and generally can keep it if they leave, though your money stops. CMS says the arrangement is funded entirely by employer contributions.
- Employees can use it for a Marketplace plan, an individual plan bought outside the Marketplace, Medicare Part A and B, or Medicare Advantage.
- You can offer it to all employees or to certain classes, such as full time, part time, seasonal, salaried, hourly or employees in the same rating area. The rules list the classes, and you cannot make up your own.
- Within a class, the amount can vary only by age (up to a 3 to 1 ratio) and by the number of dependents covered.
- You generally must give written notice 90 days before the plan year, and you can set a waiting period for new hires.
- If you also offer a group plan, you cannot give the same class of employees a choice between the two. A class size minimum, 10 employees if you have fewer than 100, applies when you offer both.
An offer that counts as affordable ends an employee's eligibility for the premium tax credit. For 2026 plans, a CHOICE arrangement is affordable when the employee's cost for the lowest cost silver plan in their area, after your reimbursement, is less than 9.96% of household income. For 2027 the figure is 10.22%.
How does a QSEHRA work?
A QSEHRA lets a small employer reimburse employees tax free for premiums and some other medical costs, up to a yearly cap set by the IRS. For 2026 the cap is $6,450 for employee only coverage and $13,100 for a household. The 2027 limits had not been published when we reviewed this guide on October 26, 2026.
- You must have fewer than 50 full time employees and offer no group health plan, including a flexible spending account.
- You provide it on the same terms to all full time employees. Amounts can vary only by age and by the number of people covered.
- You give written notice when a new employee becomes eligible and 90 days before each plan year for current employees.
- Employees must have qualifying health coverage to use it. If an employee does not claim the money, you keep it.
- Employee only
- Household
- 2019Employee only: $5,150Household: $10,450
- 2020Employee only: $5,250Household: $10,600
- 2021Employee only: $5,300Household: $10,700
- 2022Employee only: $5,450Household: $11,050
- 2023Employee only: $5,850Household: $11,800
- 2024Employee only: $6,150Household: $12,450
- 2025Employee only: $6,350Household: $12,800
- 2026Employee only: $6,450Household: $13,100
Source: HealthCare.gov: Health Reimbursement Arrangements (HRAs) for small employers
How do these options affect my employees' Marketplace savings?
An offer that is affordable ends an employee's eligibility for the premium tax credit. An offer that is not affordable leaves the employee a choice. The details differ for each option.
| Option | If the offer is affordable | If the offer is not affordable |
|---|---|---|
| Small group plan (SHOP) | The employee is generally not eligible for a premium tax credit | The employee may enroll in a Marketplace plan and may be eligible for a premium tax credit |
| CHOICE arrangement | The employee and covered dependents are not eligible, even if they decline the offer | The employee can choose the CHOICE arrangement or the premium tax credit, but not both |
| QSEHRA | The employee and covered dependents are not allowed a premium tax credit | The employee must reduce the advance premium tax credit by the QSEHRA amount |
HealthCare.gov offers affordability tools for employers and employees, and a licensed agent can help you test an offer before you make it.
Can I offer both a group plan and a CHOICE arrangement?
Yes, but not to the same employees. You can offer a group plan to one class, such as full time employees, and a CHOICE arrangement to another, such as part time employees. You cannot combine a CHOICE arrangement with a group plan or SHOP coverage for the same people.
If you offer a group plan, you may also add an excepted benefit HRA to reimburse things like dental, vision, coinsurance and copayments. The limit is $2,200 for plan years beginning in 2026 and $2,250 for 2027.
Which option fits my business?
It comes down to three questions: do you want the tax credit, how many full time employees do you have, and do you want to pick the plan or set a budget? These pairings follow the rules above.
- You want the Small Business Health Care Tax Credit: only SHOP group coverage can earn it.
- You have fewer than 50 full time employees and want a capped, predictable budget: a QSEHRA fits, within the yearly limit.
- You want no yearly limit, different amounts for different classes of employees or employees spread across areas: a CHOICE arrangement fits.
- You want one plan, chosen by you, for the whole team: a group plan fits.
- You have 50 or more full time employees: the employer mandate applies, and CHOICE eligibility choices can affect it. Talk to a licensed agent before you decide.
Our quote form lets you say which you want to compare. A licensed agent can show a group plan and a CHOICE arrangement budget side by side.
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Enter your full-time and part-time employees to see your full-time equivalent count, which rules apply to you and what the small business health care tax credit could be worth.We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options.
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