Answers · Eligibility & rules
What employee classes can an ICHRA use?
The regulations permit eleven classes, including full-time, part-time, seasonal, salaried, hourly, employees in a defined rating area, and employees covered by a collective bargaining agreement.
Classes exist so an employer can treat genuinely different groups differently without discriminating inside a group. Allowances can vary between classes, and within a class they can vary only by age and by family size. Everyone in the same class must get the same offer on the same terms.
You cannot offer one class a choice between an ICHRA and a traditional group plan; a class gets one or the other. Where an employer keeps a group plan for one class and offers an ICHRA to another, minimum class size rules apply to prevent the arrangement being used to move only the expensive people off the group plan.
In practice the geographic class is the one that most often solves a real problem: a company with staff in several states can offer an ICHRA where the local individual market is strong and keep a group plan where it is not.
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
How many classes are permitted?
Eleven, including full-time, part-time, seasonal, salaried, hourly, employees in a defined rating area, and employees covered by a collective bargaining agreement.
Can allowances differ between classes?
Yes. Between classes they can differ freely; within a class they can vary only by age and by family size, and everyone in the class must get the same offer on the same terms.
Can we keep a group plan for some employees?
Yes, but not inside the same class, and minimum class size rules apply so the arrangement cannot be used to move only the expensive people off the group plan.