Contribution design • Affordability • Employee choice
Employer contribution strategy

CHOICE Arrangement employer contribution rules

Employers control the allowance, but the contribution design must follow federal rules and be applied consistently within permitted employee classes.

Core ruleThe employer funds the arrangement. Employees generally must be enrolled in individual health insurance or Medicare that satisfies the applicable requirements before eligible expenses can be reimbursed.

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.