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Reference

ICHRA glossary

Plain-English definitions of the ICHRA, QSEHRA, and health-benefit terms you’ll run into — from affordability and safe harbors to employee classes and substantiation.

ICHRA
Individual Coverage Health Reimbursement Arrangement — an IRS-approved benefit that lets an employer of any size reimburse employees tax-free for individual health insurance instead of offering a group plan.
QSEHRA
Qualified Small Employer HRA — a capped version of the ICHRA idea for employers with fewer than 50 employees, with an annual IRS contribution limit and uniform terms.
HRA
Health Reimbursement Arrangement — an employer-funded arrangement that reimburses employees tax-free for qualified health expenses. ICHRA and QSEHRA are types of HRA.
EBHRA
Excepted-Benefit HRA — a limited, capped HRA that supplements other coverage (for costs like dental, vision, and copays) and cannot be an employer's primary medical benefit.
GCHRA
Group-Coverage (Integrated) HRA — an HRA that sits on top of a traditional group health plan to reimburse out-of-pocket costs; it requires a group plan to exist.
MERP
Medical Expense Reimbursement Plan — the Section 105 mechanism underneath HRAs. Today's ICHRA, QSEHRA, and EBHRA are all MERPs structured to meet current rules.
Section 105
The part of the tax code that allows employers to reimburse employees' medical expenses tax-free. It is the legal basis for HRAs.
Allowance
The monthly amount an employer offers each employee (or class) through an ICHRA to spend on individual coverage and, if permitted, other medical costs.
Reimbursement
The tax-free payment an employer makes to an employee for a substantiated health expense, up to the allowance.
Affordability
The IRS test that determines whether an ICHRA offer is 'affordable': the employee's cost for the lowest-cost Silver plan minus the allowance must be within a set percentage of income (9.96% for 2026).
Safe Harbor
An IRS-approved method for proving affordability without knowing an employee's household income. The three are the Federal Poverty Line, Rate of Pay, and W-2 wages methods.
FPL Safe Harbor
Uses the Federal Poverty Line to set a fixed monthly affordability cap (about $129.90 for 2026), the simplest way to guarantee an offer is affordable.
Rate of Pay Safe Harbor
Bases affordability on an employee's hourly wage times 130 hours, or monthly salary, instead of actual household income.
W-2 Safe Harbor
Uses the employee's W-2 Box 1 wages as the income basis for the affordability test.
Lowest-Cost Silver Plan (LCSP)
The cheapest Silver-tier plan available to an employee in their area. Its self-only premium is the benchmark used to test ICHRA affordability.
SLCSP
Second-Lowest-Cost Silver Plan — the benchmark used to calculate premium tax credits (subsidies) on the marketplace.
Premium Tax Credit (Subsidy)
An income-based ACA subsidy that lowers marketplace premiums. An employee offered an affordable ICHRA generally cannot also claim it.
Metal Tiers
The four ACA plan levels — Bronze, Silver, Gold, and Platinum — that trade premium for out-of-pocket cost. Higher tiers cost more monthly but cover more.
Minimum Essential Coverage (MEC)
Coverage that satisfies the ACA's individual and employer requirements. ACA-compliant individual plans qualify.
Individual Market
The market where people buy their own health plans (on or off the exchange), as opposed to employer group coverage. ICHRA runs on this market.
On-Exchange / Off-Exchange
On-exchange plans are bought through the ACA marketplace (and can use subsidies); off-exchange plans are bought directly from an insurer. ICHRA reimburses both.
Marketplace / Exchange
The platform where individuals shop for ACA plans — HealthCare.gov in most states, or a state-run exchange in others.
Special Enrollment Period (SEP)
A window, often 60 days, to buy individual coverage outside open enrollment — triggered by events like a new ICHRA offer, marriage, or a new child.
Open Enrollment
The annual period when anyone can enroll in or change an individual health plan.
Employer Mandate
The ACA requirement that Applicable Large Employers offer affordable, minimum-value coverage or face penalties. An affordable ICHRA satisfies it.
Applicable Large Employer (ALE)
An employer with 50 or more full-time-equivalent employees, subject to the ACA employer mandate and 1095-C reporting.
Employee Class
A permitted grouping of employees (like full-time, part-time, seasonal, or by geography) that an employer can offer different ICHRA allowances to.
Minimum Class Size
A rule requiring a minimum number of employees in a class when an ICHRA is offered alongside a group plan — 10, 10%, or 20 depending on employer size.
Substantiation
Proof that an employee has qualifying coverage and actually incurred an expense, required before an HRA reimbursement can be paid tax-free.
Plan Document
The written legal document that establishes an ICHRA's terms — eligibility, classes, allowances, and rules. Required for compliance.
ICHRA Notice
The written notice an employer must give eligible employees, generally at least 90 days before the plan year, explaining the ICHRA and its effect on subsidies.
Rating Area
A geographic area (based on counties/ZIPs) that insurers use to set individual-market premiums. It's why ICHRA pricing changes by location.
Age Curve
The federal schedule that lets insurers charge older enrollees more, up to a 3:1 ratio, for the same plan. It's why premiums rise with age.
HSA
Health Savings Account — an employee-owned, pre-tax account for medical costs, available with HSA-eligible high-deductible plans. Can coexist with a compatible HRA.
FSA
Flexible Spending Account — an employee-funded, pre-tax account for out-of-pocket medical costs, usually with use-it-or-lose-it rules.
Minimum Value / Actuarial Value
A measure of how much of expected costs a plan covers. Silver plans sit near 70% actuarial value, which is why Silver is used for benchmarks.
CHOICE Act
Proposed federal legislation (Custom Health Option and Individual Care Expense) that would codify ICHRA into statute rather than leaving it to regulation.
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