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Some Employers Are Setting Up ICHRA Programs: Take Command Health

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Take Health Command — a health reimbursement arrangement (HRA) support services firm —is seeing strong early employer interest in the new “individual coverage HRA,” or ICHRA.

About 20% of the company’s new sales prospects are asking about the ICHRA program, according to Amy Skinner, a Take Health Command representative.

(Related: 3 Important Details in the New Individual Coverage HRA Regs)

“We’ve had some early enrollments already, despite just launching on the first,” Skinner said in an email interview.

The enrollment transactions involve employers setting up ICHRA plans and having the plans ready to provide cash for coverage for employees in January, Skinner said.

The number of people looking at the firm’s ICHRA website section has increased dramatically, and broker interest in the firm’s ICHRA webinar series has been strong, Skinner said.

“We had over 100 participants on the last one,” Skinner said. “Most [attendees] are brokers trying to figure out ICHRA because their clients have asked.”

Employers of all sizes seem to be interested in the ICHRA concept, Skinner said.


An HRA is a personal health benefits account that leaves ownership of the account value in the hands of the employer. An employee can roll value over from one year to the next but must keep any unused value in the employer’s HRA plan.

In the past, federal regulators discouraged use of HRAs as a vehicle for giving employees cash they could use to pay for individual coverage, because of concerns that cash-for-coverage HRAs could destabilize the traditional group health market.

Under the administration of President Donald Trump, regulators have created a framework employers can use to offer cash-for-coverage programs, by setting up an ICHRA.

Regulators have imposed a number of restrictions an employers must use to keep an ICHRA program from discriminating against employees with health problems, or from leaving some employees without health coverage.

An employer can put an unlimited amount of cash in ICHRA but must offer either an ICHRA to all employees in a given class of employees or a traditional group health plan. An employer cannot give an employee a choice between an ICHRA or a traditional group health plan.

The Trump administration has predicted that 800,000 employers could use ICHRA to provide health benefits for 11 million people. Some benefits specialists have suggested that the antidiscrimination provisions could limit ICHRA uptake.

— Read Does DOL’s HRA Proposal Go Far Enough? Bloink & Byrnes Go Thumb to Thumbon ThinkAdvisor.

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