How to Set Up an ICHRA Allowance Structure

Learn what to establish when designing your ICHRA allowance structure and how to apply amounts consistently across employee classes.

Sep 7, 2026

Before the plan year begins, establish the allowance structure for each employee class.

Your plan should define:

  • The amount or formula applicable to each class

  • Whether amounts vary by age

  • Whether amounts vary by family size

  • Which dependents may be included

  • How amounts are handled for employees who become eligible during the year

  • How family changes are handled during the year

  • Whether unused amounts carry forward

  • Effective dates for the structure

There is no general federal minimum or maximum ICHRA contribution amount. The structure still needs to follow the applicable ICHRA rules and your plan documents.

Employees within the same class generally receive the ICHRA on the same terms, subject to permitted variations such as age and family size.

Do not create an individual exception and describe it as a class. Employees of the same age and family status within the same class should not receive different amounts because one selected a more expensive policy, uses more medical care, or requested an exception.

Different employee classes may have different allowance structures when the classes and offers comply with the applicable ICHRA rules.

Do not begin employee enrollment while the allowance model is still changing. The allowance affects employee decisions, affordability results, notices, payroll coordination, and employer reporting.

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