Can contributions vary?
They may vary by permitted employee class. Within a class, amounts may also vary based on age and family size when the design follows applicable limits. Geography matters because individual premiums and affordability benchmarks differ by location.
Employee, spouse and dependent offers
Model the employee-only amount first, then decide which family members will be offered the arrangement. If the employee’s self-only ICHRA is affordable, an offered spouse or child generally cannot receive PTC—even if the family offer is only $1 or is waived. Applicable large employers should have the administrator or ERISA/ACA counsel review dependent-child offer duties; excluding children can create §4980H exposure.
What employers should document
- Eligible employees and permitted classes
- Monthly employee-only allowance
- Spouse and dependent offer terms
- Age or geographic variations used
- Plan year and eligibility dates
- Rollover treatment and reimbursable expenses
- Opt-out, substantiation and reimbursement procedures
Avoid the taxable-stipend shortcut
Reimbursing individual premiums outside a compliant arrangement can create regulatory and tax problems. Use formal plan documents and qualified administration.
Planning information only. Confirm the final design with the administrator and qualified benefits or legal advisers.