ICHRA vs QSEHRA side by side
| QSEHRA | ICHRA (CHOICE Arrangement) | |
|---|---|---|
| Employer size | Fewer than 50 full-time employees, including equivalents | Any size, with at least one non-owner employee |
| 2026 limit | $6,450 self-only, $13,100 family | No federal minimum or maximum |
| Who gets it | All eligible employees on the same terms | All employees or chosen classes (full-time, part-time, location and others) |
| How amounts can vary | By age and number of people covered | Within a class, by age (up to 3 to 1) and number of dependents |
| Group plan at the same time | Not allowed (including a health FSA) | Allowed for other classes, not the same class |
| Coverage employees need | Minimum essential coverage, including a spouse's job plan, Marketplace, Medicare or Medicaid | Individual coverage: Marketplace, off-Marketplace individual plan or Medicare |
| Premium tax credit | Affordable: no credit. Unaffordable: credit reduced by the QSEHRA amount | Affordable: no credit. Unaffordable: employee picks the ICHRA or the credit |
| Employee notice | 90 days before each plan year; new hires by their first eligible day | 90 days before each plan year; new hires when eligible |
When a QSEHRA tends to fit
- You have fewer than 50 full-time employees and no plans to grow past that soon.
- You want one simple allowance for everyone, within the yearly cap.
- Some employees are covered through a spouse's job plan. A QSEHRA can reimburse them, because any minimum essential coverage counts, while an ICHRA requires individual coverage.
- You don't offer a group plan or a health FSA, and don't want to.
When an ICHRA tends to fit
- You want to give more than the QSEHRA cap, or set different amounts for full-time and part-time staff or for different locations.
- You expect to reach 50 or more full-time employees. A QSEHRA ends when you become an applicable large employer; an ICHRA can continue, and the IRS has rules for testing its affordability under the employer mandate.
- You want to keep a group plan for one class and offer an ICHRA to another.
- Some employees are on Medicare. HealthCare.gov counts Medicare Part A and Part B, or Part C, as qualifying coverage for an ICHRA.
Where Gabriel fits
Whichever you choose, employees buying their own plan can get Marketplace quotes from Gabriel and finish their own application with a licensed agent in most states. Employers with 25 or more employees can add Gabriel for Teams, a care membership, alongside a health plan. It is not group health insurance and not an HRA, QSEHRA or ICHRA, it doesn't replace a health plan, and it never satisfies the ACA employer mandate.
Gabriel is not an insurer. Health insurance quotes and enrollment are handled by Gabriel Labs, Gabriel's separately licensed insurance agency. This page is general information; check plan design with a benefits attorney or tax advisor.
Common questions
Is an ICHRA or a QSEHRA better for a small business?
It depends on your goals. A QSEHRA is simpler and fits employers under 50 who want one allowance within the yearly cap. An ICHRA fits if you want classes, larger amounts, or room to grow past 50.
Can I offer both an ICHRA and a QSEHRA?
No. A QSEHRA employer can't offer any other group health plan, and an HRA such as an ICHRA is itself a group health plan, so you choose one.
Which has a contribution limit?
Only the QSEHRA. For 2026 it's $6,450 self-only and $13,100 family. An ICHRA has no federal minimum or maximum.
Can employees on a spouse's plan use these?
A QSEHRA can reimburse employees with any minimum essential coverage, including a spouse's job plan. An ICHRA requires individual coverage or Medicare.
What is a CHOICE Arrangement?
It's the name HealthCare.gov now uses for the individual coverage HRA (ICHRA). The page describes the same rules on classes, notices and affordability.
Sources
- Find the right HRA for your business HealthCare.gov
- CHOICE Arrangements (formerly individual coverage HRAs) HealthCare.gov
- Qualified Small Employer HRA (QSEHRA) HealthCare.gov
- Rev. Proc. 2025-32: 2026 inflation-adjusted items (section 4.63) IRS
- Health Reimbursement Arrangements (HRAs) IRS
This guide is general information, not medical advice. It does not replace a visit with a licensed clinician. Gabriel membership is not health insurance.