There is no federal minimum or maximum. Unlike a QSEHRA, which caps reimbursements each year, an ICHRA lets you contribute whatever you choose. What the rules control is who gets how much — so that the amount is set by objective groups, not by individual.
Rule 1: the same amount within a class
You can offer different amounts to different classes of employees, but everyone in a class gets the same terms. The regulations define the classes you can use:
- full-time employees and part-time employees;
- seasonal employees;
- salaried employees and non-salaried (for example, hourly) employees;
- employees covered by a collective bargaining agreement;
- employees who haven't completed a waiting period;
- non-resident aliens with no U.S.-source income;
- employees whose primary work site is in the same geographic rating area;
- employees of a staffing firm placed with a customer;
- and combinations of two or more of the above.
You can't create your own classes, such as by job title or by department.
Rule 2: what can vary within a class
Age — up to 3 to 1
Individual premiums rise with age, so you can give older employees more. The most anyone in a class receives can't be more than three times what the youngest employee in that class receives, and everyone of the same age must get the same amount.
Family size
You can give more to employees who also cover a spouse or children.
Rule 3: class-size minimums — only when mixing with a group plan
If you offer a traditional group plan to some employees and an ICHRA to others, certain classes (full-time, part-time, salaried, hourly, and some geographic classes) must meet a minimum size:
| Feature | Minimum class size |
|---|---|
| Fewer than 100 employees | 10 employees |
| 100 to 200 employees | 10% of employees |
| More than 200 employees | 20 employees |
If you don't offer a group plan to anyone, these minimums don't apply.
Rule 4: affordability, if you have 50+ full-time equivalents
Applicable large employers need their ICHRA to be affordable to satisfy the employer mandate. The test: the cost of the lowest-cost silver plan available to the employee, for self-only coverage, minus your monthly allowance, must be no more than 9.96% of their monthly household income for 2026 plan years (10.22% for 2027).
Because you don't know employees' household incomes, you can use the same safe harbors as group plans — W-2 wages, rate of pay, or the federal poverty line. The poverty-line safe harbor is the simplest and the most conservative:
Two more safe harbors help: you can measure the benchmark plan by the employee's work location rather than home, and use plan prices from a fixed look-back month rather than updating monthly.
Below 50 full-time equivalents there's no penalty — but affordability still decides whether employees can get a Marketplace subsidy instead. More on affordability and subsidies.
So how should you choose a number?
Start from what the business can sustain, then check it against real plan prices for your team. The Rikor calculator does that with your employees' ages and locations, and shows who might be better off with a subsidy.
Sources
- HealthCare.gov — CHOICE Arrangements (for employers)
- 26 CFR 54.9802-4 — Special rule allowing integration of HRAs with individual health insurance
- CMS — Individual Coverage HRA frequently asked questions (PDF)
- IRS Rev. Proc. 2025-25 — 2026 required contribution percentage (9.96%)
General information, not tax, legal or insurance advice. Rules change and individual situations differ — confirm specifics with your tax adviser or benefits counsel.