ICHRA was prioritized by the US House Ways and Means Committee, the House committee of jurisdiction for health reimbursement arrangements, at the end of 2024. In December, the HRA Council and other stakeholders received a public Request for Information (RFI) on ICHRA from the office of Rep. Kevin Hern (R-OK), Ways and Means Committee Member and sponsor of the 2023 CHOICE Arrangement Act, ultimately sent back to Committee, which sought to establish statutory authority over ICHRA and other alternative health insurance options for employers. The Council responded to the RFI and is now making the full text of our response available to the public.

This official HRA Council response was developed through close collaboration among our leadership and Members. We believe it represents the best interests of the widest set of health insurance stakeholders, including those employers, health insurance professionals, and US workers who remain unaware of ICHRA's growth, advantages, or even existence.

Here are some key takeaways from our response:

• ICHRA is in great working order as a proven, increasingly popular solution to known challenges in the Employer-Sponsored Health Insurance markets;
• A small set of specific process and regulatory fixes would further reduce the administrative, cost, and change management burdens or disparities in providing ICHRA as a health benefit, while improving the Employer and Employee experience;
• As a Council, we support further consideration of provisions to allow for Employers to offer both traditional group coverage and ICHRA to their entire workforce, further expanding flexibility and choice for both Employers and Employees, already hallmarks of ICHRA as a health benefit option;
• Much more awareness and education should be propagated by the Tri-Agencies overseeing ICHRA, on par with the resources made available to Employers and Employees for understanding other Employer-sponsored benefits.

Click here or the link in the "Comment Letters" section of hracouncil.org/action to see our full response.

For questions, please email robin@hracouncil.org.