Answers · Eligibility & rules
Which group insurance arrangements have the least restrictive eligibility rules?
Individual Coverage HRAs have the least restrictive eligibility rules of the common arrangements, because they impose no minimum participation percentage and no minimum employer contribution.
Ranked from most to least restrictive in practice: fully insured small group plans, which typically require around 70% participation and a 50% employer contribution; level-funded plans, which add medical underwriting of the group on top; association or PEO arrangements, which add membership or co-employment conditions; and Individual Coverage HRAs, which impose neither a participation floor nor a contribution floor.
An ICHRA does carry its own rules, and they are about fairness rather than volume. You must offer it on the same terms to everyone inside a permitted employee class, you cannot offer the same class a choice between the ICHRA and a traditional group plan, and employees must be enrolled in individual coverage for the allowance to be used.
For an employer who keeps failing participation because employees are covered elsewhere, or who has a workforce spread across many states and cannot find one network that works, the eligibility difference tends to matter more than the premium difference.
Last reviewed 2026-08-21. Premium figures are plan year 2026 on both sides of every comparison, from the CMS Marketplace Public Use Files (individual market) and Ideon (small group). Employer counts from BLS QCEW 2024 Q2. All savings figures are ranges and estimates, not quotes or guarantees.
Related questions
Which arrangement is the most restrictive?
Fully insured small group, which typically requires around 70% participation and a 50% employer contribution, followed by level-funded plans that add medical underwriting of the group on top.
What rules does an ICHRA impose instead?
Fairness rules rather than volume rules. The same terms must be offered to everyone in a permitted employee class, a class cannot be offered a choice between the ICHRA and a group plan, and employees must hold individual coverage to use the allowance.
Does a PEO or association plan avoid participation rules?
Not really. It replaces them with membership or co-employment conditions, so the constraint moves rather than disappears.