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May 26, 2025

Takeaways from Our ICHRA Webinar

Our recent ICHRA webinar sparked an energetic discussion with a wide range of insightful questions from attendees. We were thrilled to see so much engagement around a topic that is transforming how employers offer health benefits. To ensure you don’t miss a beat, we’ve compiled a comprehensive recap of the most commonly asked questions—and the expert answers provided during the session.

1. Can ICHRA Funds Be Used to Cover a Spouse’s Insurance Premium?

Yes. If you are covered under your spouse’s plan, you can use ICHRA funds to pay the employee portion of those premiums, assuming that plan meets the ICHRA’s eligibility criteria. This allows for flexible coverage while still utilizing employer-provided benefits.

2. Can Employees Have an HSA Alongside an ICHRA?

Yes—but only if the employee enrolls in a High Deductible Health Plan (HDHP). HSAs can be paired with an ICHRA as long as the coverage is HSA-compatible.

3. Can Off-Exchange Plans Be Pre-taxed?

Yes. Whether a plan is on or off the marketplace exchange, employees can make pre-tax contributions to help cover the cost above what the ICHRA provides. However, a Premium Only Plan (POP) is required to enable pretax deductions.

4. Is ICHRA Available in Every State?

Yes. ICHRAs are available anywhere individual health plans are offered. That said, the quality and variety of plans vary by state. For example, states like Minnesota and New Mexico have robust individual markets, while others like Texas may offer fewer options.

5. Are Employer Contributions Typically Set at ACA Affordability Levels?

For Applicable Large Employers (ALEs), yes. Contributions are generally set to meet ACA affordability standards, which Ameriflex can help calculate using our affordability tool. For non-ALEs, contribution levels vary more widely.

6. Does the Ameriflex Portal Show All Marketplace Plans?

Yes. The Ameriflex platform displays all available plans from carriers in the individual market. It is not limited to Ameriflex-specific offerings, and it adheres to ICHRA compliance rules by avoiding any plan recommendations or limitations on employee choice.

7. Is There a Minimum Group Size for ICHRA?

No. Ameriflex does not impose a minimum group size or participation requirement. We currently serve groups as small as two employees and as large as nearly 2,000.

8. What’s the Best Way to Present ICHRA to an Employer Offering a Group Plan?

A side-by-side demo of the quoting and plan comparison tool is the most effective approach. It allows employers to compare costs and coverage options directly against their current group plan. Ameriflex can provide these demos, including affordability calculators tailored to specific employee locations.

9. Can Employers Buy Down Deductibles on Individual Plans?

While Ameriflex does not provide plan design recommendations, employers can use ICHRA class structures to offer different reimbursement amounts to groups such as union members. This can help employees select richer coverage without violating ICHRA rules.

10. What Happens to Unused ICHRA Funds?

Unused funds at the end of the plan year typically revert back to the employer. However, ICHRA dollars can be used for other qualified medical expenses under IRS Section 213(d), including dental and vision costs, so employees are encouraged to use their funds wisely.

11. Can Unused ICHRA Funds Be Rolled into an HSA?

No. ICHRA funds cannot be redirected into an HSA—even a spouse’s HSA. The funds must be used for eligible expenses within the ICHRA structure and cannot be withdrawn or transferred.

12. Do Agents Retain Commissions and Book of Business?

Yes. Ameriflex does not assume broker-of-record (BOR) status or interfere with agent commissions. Brokers remain central to the process and can continue servicing clients and receiving commissions directly from the carriers.

13. Can the Platform Be Used for Quoting Individual Plans Outside of ICHRA?

Currently, the platform is designed specifically for ICHRA. However, we are open to evolving it into a broader quoting tool for individual health plans. Interested agents or GAs are encouraged to reach out and explore future opportunities.

14. Can Employers Access the Affordability Calculator Without Going Through a Broker?

Yes. Ameriflex can send a census form directly to the employer, and we’ll run the calculations internally—no broker required.

15. Can ICHRA Be Offered to Retirees Only?

Not as a standalone class. Retirees must fall into one of the predefined ICHRA classes (e.g., based on location). Employers can structure reimbursements based on these classifications, but retirees alone cannot form a separate class.

16. Does ICHRA Require 100% Participation?

No. Employers are only responsible for funding accounts and paying administration fees for employees who opt into the ICHRA. Participation is entirely voluntary.

17. Is There a Setup Fee for ICHRA?

Yes, a small one-time setup fee applies, along with a monthly per-employee (PEPM) administration fee. For our The Ameriflex Alternative Plan (TAAP) product, a monthly minimum fee may also apply.

Thank You for Joining Us!

We’re grateful to everyone who attended our webinar and contributed to such a rich conversation. If you’d like a demo or have specific scenarios you’d like to explore, don’t hesitate to reach out. Just press the button below to request a proposal. We’re here to help you navigate ICHRA with confidence.

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