“ICHRA” Individual Coverage Health Reimbursement Arrangement

Saving small business and their employees! This time the Government has listened and extended the olive branch. In its simplest term, an ICHRA will allow businesses the alternative to offer employees a monthly allowance of tax-free money. It allows them to buy individual health coverage tailored to fit their unique needs, control costs. ICHRA’s also include provisions for out of pocket health insurance expenses, and address ACA compliance for employers with more than 50 employees.

For years, companies had been able to leverage HRAs to reimburse their employees’ healthcare expenses. The Affordable Care Act (ACA), specifically IRS Notice 2013-54, limited a business’s ability to offer HRAs to their employees for individual policies. Although the qualified small employer HRA (QSEHRA) helped some small businesses, there were still many restrictions and roadblocks to leveraging HRAs for employees.

In 2017, an Executive Order was issued directing the Departments of Treasury, Health and Human Services, and Labor to expand business’ use of HRAs once again. In June of 2019, new rules were released, establishing ICHRA as an option beginning on January 1, 2020.

This new allowance, and the ability to offer it, is available to companies of all sizes from just a handful of employees to larger corporate entities. Removing the complexity of traditional group insurance plans, ICHRA brings a long list of benefits to both employers AND employees. Not only does ICHRA provide flexibility in how much a business chooses to spend, it also allows for different levels of contribution based on different employee classes.

The process for implementing ICHRA benefits is simple, and its design allows employees to choose the plan and benefits that best meet their unique needs. From an administration perspective, ICHRA’s method is straight-forward. An employer decides what allowance each employee class will receive. Then, employees make their health care purchases, including insurance, and submit proof of their expenses. Within the allotted allowance amount, the company reimburses them for those expenses. It’s that easy!

Who’s eligible? As long as an employee has coverage under an individual health insurance policy, and the employer chooses to include their employee class in the ICHRA, they’re eligible.


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Joel White

Horizon Government Affairs

Horizon Government Affairs was founded in 2007 by Joel White, a veteran of Capitol Hill who served as staff director for the Ways and Means Health Subcommittee. Since then, we have built an impressive bipartisan team of thought leaders and problem solvers with decades of experience in securing wins for our clients.
As experts in our field, we help our clients pass legislation, change regulations, testify to Congress, and drive the conversation on emerging issues. We do this through creative policy development, data driven-insights, innovative issue campaigns and advocacy strategies and through coalitions of allies we have cultivated for years.
Horizon Government Affairs is trusted by lawmakers, influencers and clients alike because we lead with integrity and get it right the first time.

Jennifer Berman, Esq.

Compliance Officer

Jen Berman is an employee benefits attorney. In that capacity, Jen routinely negotiates service contracts and drafts employee benefit plans, summary plan descriptions and employee communications. She also reviews client benefit programs for compliance with the Internal Revenue Code, ERISA, HIPAA, COBRA, ACA, wellness plan rules and other applicable statutes.

Since the passage of the Affordable Care Act in 2010, Jen has also become an “ACA compliance educator.” She is a leader in analyzing health care reform developments and frequently serves as a speaker and commentator on a wide variety of health care reform and employee benefits issues.

In addition to serving as CEO of MZQ Consulting, LLC, Jen is also a member of Holder Law Group LLC. Prior to joining Holder Law, Jen practiced at Venable LLP as part of their Employee Benefits and Executive Compensation practice group. Jen graduated cum laude from the University of Pennsylvania Law School, where she was Editor-in-Chief of the University of Pennsylvania Journal of Labor and Employment Law. Jen also completed her undergraduate studies at the University of Pennsylvania, graduating magna cum laude with a Bachelor’s of Arts in Political Science. She is an avid lover of textile arts, frequently wearing stunning pieces she has hand-crafted herself.

Alan Schulman

Alan Schulman
Alan Schulman is President of Insurance Benefits and Advisors. IBAA is a leading diversified comprehensive insurance brokerage and advisory practice specializing in life insurance, health and welfare services, retirement plan consulting, property & casualty insurance, and wealth management. Alan started his career in 1980 as a Certified Financial Planner and transitioned into the insurance industry in 1988 to work with company owners on their employee benefits. Alan is licensed in health, life, long term care and all lines of business insurance, and assists top executives in creating and preserving wealth and a secure retirement. Alan is past President of The Greater Washington National Association of Health Underwriters (GWAHU) and is past President of the Maryland Association of Health Underwriters (MAHU). He is a lifetime member of the Leading Producers Round Table of the National Association of Health Underwriters (NAHU), and was appointed in 2010 to sit on the Board of Directors for NAHU’s political action committee, the Healthcare Underwriters Political Action Committee (HUPAC). On March 6th, 2014 Alan testified before the U.S. Congressional Small Business Committee, representing NAHU and his client CAHC.org, on the impact of the Patient Protection and Affordable Care Act (PPACA, commonly referred to as “Obama Care”), on small and medium size businesses. Alan currently serves on the Joint Legislative Task Force in Maryland, and meets with legislators in Annapolis to assist in the creation of laws that positively affect the cost of health insurance. He was an original member of the MD and DC Health Insurance Exchange Advisory Committees. Passionate about serving his community, Alan is a member of the Maryland Nonprofits Association and Maryland Association of Community Services (MACS). In 2014, he served on the Board of Directors for Hearts & Homes for Youth, a non-profit organization serving young survivors of neglect and abuse. Alan is a board member with JCRC. He is also an active member of the Metro Bethesda Rotary Club. Alan and his wife Robin have been married for 35 years and have resided in Olney Maryland for 33 years, where they raised their two daughters.

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