Chat Bubble
Skip to main content

We’ve dedicated a considerable amount of time in recent months exploring the benefits and advantages companies are leveraging with the Individual Coverage Health Reimbursement Arrangement. But with so many ICHRA dynamics to consider, you might still have a few remaining unanswered questions before making the switch to an ICHRA model for your company. So today, we’ll highlight some of the most prevalent and common ICHRA questions company leaders and agencies ask, along with the answers you need to make the right benefits platform decision for your business model.

ACA Compliance & Exchange-Related ICHRA Questions

Some of the most common ICHRA questions we encounter are rooted in compliance and clarifications for ACA and exchange-based platforms. Here are a few of those compliance and mandate-related inquiries that tend to come up most in ICHRA discussions.

Does an ICHRA Work with

Yes! ICHRAs can be used for health plans both on and off the exchange. Open Enrollment is happening through December 15, meaning ICHRA participating employees can be shopping for and enrolling in ACA health plans right now.

Does an ICHRA Work with State-Based Exchanges?

Yes. ICHRAs can be used for health plans both on and off the exchange at the state level, including SBM states.

Does the ICHRA Meet the Large Group ACA Mandate?

Yes. The large group mandate is still in effect. However, ICHRAs work with the 11 employee classes to direct employees to shop for individual plans allowing the sponsored employer to not be penalized for not having met the requirements of the ACA mandate.

Does an ICHRA Require a Third-Party Administrator?

Not necessarily. While it’s not required, it’s definitely recommended that companies partner with TPAs to help launch, manage, and analyze the ICHRA platform. A TPA can stay on top of ever-changing requirements, participation, and reimbursements on an employer’s behalf.

Does an ICHRA Only Make Sense for Large Employers?

No. Adopting an ICHRA with its customizable flexibility in budgets and reimbursements is a smart move for a variety of business sizes across any industry segment.

Employee-Level ICHRA Questions

Before transitioning away from a traditional group health insurance plan to an ICHRA, you likely have employee-level ICHRA questions that need answers. These are a few of the most common we tend to see.

How Does the APTC Work with ICHRA?

An ICHRA benefit is a group benefit offered by an employer to an employee. APTC (Advanced Premium Tax Credit) is a government subsidy offered to consumers based on their household income. But with the ICHRA in place, participating employees can apply for and leverage APTCs when they enroll in coverage through the Marketplace.

Can ICHRAs Work for Ancillary Coverage Products?

Yes and No. ICHRAs can be offered alongside ancillary products, like dental and vision coverage. However, it’s important to note that the ICHRA contribution cannot be used to pay for the premiums associated with ancillary coverage products.

How Does an ICHRA Relate to the Open Enrollment Period for the ACA Marketplace?

An ICHRA requires participating employees to qualify by purchasing a plan on their own, which they can do during Open Enrollment. Once a health plan is purchased by the individual, it can then be reimbursed through the ICHRA.

Is ICHRA Subject to COBRA Coverage?

Yes. The ICHRA allowance is subject to COBRA but with a caveat. In most employee situations, it makes more sense for the eligible employee to pay for their health insurance directly, rather than taking the COBRA continuation of the ICHRA allowance.

Will ICHRA Cost More or Save More?

Employees participating in an ICHRA platform through their employer will generally see reduced costs
associated with monthly premiums, out-of-pocket expenses, and in preventive healthcare services. Most ICHRA-adopting companies save more, too.

ICHRA Questions: Getting into the Agency Nuts & Bolts

There are often operational and logistical ICHRA questions that require deeper dive responses for agencies. These questions are just some of the more frequent nuts and bolts inquiries we see.

Is It Profitable to Opt for the Lower-Commissioned Individual Plans vs. the Group Plans?

Yes. As an agency, you can easily scale your business since employees can enroll themselves. In addition, enrollments completed through your personalized link will be automatically attributed to you.

How is My NPN Associated with the Employee Enrollments?

Through the dynamic W3LL platform, brokers can provide personalized URLs for employees to enroll on their own, ensuring their NPN is associated with the enrollment.

What If My Agency Isn’t Appointed with All Carriers?

If your agency is not appointed with the carrier selected, W3LL can act as a broker on your behalf and pay referral fees to the broker.

Can the Employee Payment Above the ICHRA Contribution Be Run Through a Section 125 Plan?

Yes. This payment application is called a “balance of premium plan” or HRA POP. Pre-tax dollars can be set aside to help pay for the balance of the plan premium not originally covered by the ICHRA funds.

Can ICHRA be offered to subcontractors working overseas?

No. ICHRAs only work for employees with US-based health plans that are available on US-based public or private marketplaces. However, employees who work overseas but continue to file taxes in the United States may be eligible to utilize the ICHRA.

3 Bonus Questions

One of the more popular and beneficial advantages of the ICHRA lies in the platform’s flexibility to accommodate various business dynamics. For that reason, there are always certain questions that require customized answers. Here’s how you can find the support and answers you need.

In what states is W3LL licensed?

W3LL is licensed in all 50 states.

Can W3LL Help Setup an ICHRA?

Yes! And W3LL can assist at every stage of your ICHRA consideration process, from guidelines to reimbursement analytics and opt-in data.

How Should I Connect with W3LL to Answer Additional ICHRA Questions?

Call, message our team of ICHRA experts, or send smoke signals if you have to! Just don’t let another unanswered ICHRA question keep you from taking the next step.

Talk with the W3LL team about your ICHRA questions today!


Pete English With nearly two decades in health insurance, Pete English’s diverse experience makes him uniquely qualified to help health plans and brokers leverage innovative technology in partnership with W3LL. From growing sales staff by 126% over 4 years at a large health plan, to building his own health insurance brokerage firm from scratch with over $7.2MM in annualized premium, Pete has done it all.

Pete English
(631) 681-4898


Leave a Reply