Check Affordability (Employers)

Need to figure out how much you have to offer for your ICHRA to be affordable?
Please complete the inputs below to get instant affordability results for an employee.

Are you an employee? Use our Employee Calculator

Employee Location Select the state and county where the employee lives or works (we can use either).
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State
We're working to add that state. Please email us at support@takecommandhealth.com for more information.
Employee Pay Type Select how the employee is paid.
Annual W-2 Wages Enter the employee's annual salary as it appears (or will appear) on the employee's W-2.
Hourly Rate Enter the employee's hourly rate of pay.

Your Results

ICHRA "affordability" is calculated for each employee based on a reference plan where the employee lives or works. In this case, the reference is the Lowest Cost Silver Plan (LCSP). Here's what the monthly LCSP would cost your employee each month.

Lowest Cost Silver Plan (LCSP) Premium

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Salary Results Explanation: For employees that receive an annual salary, we can calculate affordability using the "W-2 Wages" or "Federal Poverty Line" safe harbors. Below are the results. You may choose either one!

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Hourly Results Explanation: For employees that receive a hourly pay, we can calculate affordability using the "Rate of Pay" or "Federal Poverty Line" safe harbors. Below are the results. You may choose either one!

Affordability Safe Harbors

Wages

Federal Poverty Level

So, what's the big deal with affordability?
When designing your ICHRA, it’s important to understand if your reimbursement amount is considered “affordable” or “unaffordable” to your employees. Here’s why:

Affordable

Offering an “affordable” ICHRA means your employees are not eligible for premium tax credits.

If you're a large employer (over 50 employees) you must offer an affordable ICHRA to avoid penalties for not providing insurance.

Unaffordable

Offering an “unaffordable” ICHRA allows your employees to choose between the ICHRA or a premium tax credit.

If you're a small employer (under 50 employees) there may be times you'd want to intentionally offer an "unaffordable" ICHRA.

ICHRA Affordability FAQs

Here are some commonly asked questions about how affordability and our calculator works.

More ICHRA FAQs

What does "affordability" mean? Why is it important?

Under the Affordable Care Act (ACA, a.k.a "Obamacare") individuals must be covered by "affordable" health insurance coverage.

So how is "affordable" defined? For 2020, the government says that an individual has affordable coverage if they are spending less than 9.78% of their income for health insurance premiums based on a reference plan (See Revenue Procedure 2019-29). In this case, the reference plan is the lowest cost silver plan (LCSP) available to the employee on the public marketplace.

It's a little arbitrary, but that's what we have to work with!

An ICHRA offer is considered "affordable" to employees if based on the employee's income and the HRA contribution they are able to purchase the LCSP without spending more than 9.86% of their income.

High-wage employees can probably purchase "affordable" insurance (ie, spend less than 9.78% of their income) with little to no help from an HRA. Lower-wage employees will need a larger HRA contribution.

Applicable large employers (ALE), typically over 50 employees, that are subject to the ACA requirement to provide affordable insurance (sometimes called the "corporate mandate") must provide an affordable HRA in order to avoid penalties.

Smaller employers are not subject to this requirement, but will want to understand how affordability impacts employee tax credits (see below).

How do I fill out the census template?

Affordability is determined on an employee-by-employee basis. That can be tricky, so we've built an automated calculator to help!

Note: You can use your own census template if you have it as long as it has the following required fields below. Or, you can download our census form directly here. Please upload your census on this page or email it to support@takecommandhealth.com and we'll get back to you in 1-3 business days!

Required Employer Fields:

  • Employer Name (if you're a consultant and don't want us to know your client name, that's fine but please use a descriptive placeholder)
  • Employer Address (needed to calculate location safe harbor)
  • Desired HRA Start Date (needed to determine employee ages at the start of the HRA plan year)

Required Employee Fields:

  • Name (or some unique identifier)
  • Date of Birth (actual birth date works best, but number of years old can be used to estimate)
  • Wage Information (either their annual salary or hourly rate)

Optional Employee Fields:

  • Employee Address (preferably state and county, but we can translate regular street address information): This is optional but enables us to compare affordability results at the employer work location as well as the employee's home address or assigned work location
  • Number of Family Members: This is optional but allows us to estimate potential premium tax credits which may be important for ICHRA design considerations, especially if the employer is under 50 employees.
  • HRA Class: Optional, but if you know how you might want to group or split employees into different classes, this is helpful for us to know. You can learn about the available class options in the class section of our ICHRA guide.

If you have questions, please email us at support@takecommandhealth.com or chat with us online!

Which employees do I have to include in the affordability analysis?

Great question!

The answer is "it depends". Let us explain a little bit:

Determining whether or not you an ALE (Applicable Large Employer)?

Large employers are subject to the "corporate mandate" and must offer "affordable" benefits to their employees or face penalties. To determine if you or your client is an ALE, you have to look at all employees. This includes full-time and part-time employees and sometimes even seasonal employees, interns, etc. The reason is part-time employees are added together into "full-time equivalents" (FTE). If you have more than 50 FTEs, then you are an ALE. Congrats!

You can find more details in IRS Section 4980H. Here's a really helpful FAQ for determining how to count your employees.

If you are an ALE...

Then you will want to offer an affordable ICHRA to your full-time employees (30 or more hours/wk or 130 hours/month). You're liable for penalties if one of your full-time employees is able to get a tax credit because your ICHRA is not affordable.

You can still offer the ICHRA to part-time and other employees, but they don't really matter as much for determining potential penalties (but they count for determining if you are an ALE!).

So, if you're an ALE, to run an affordability analysis, we really only care about your full-time employees.

If you're a small employer (not an ALE)...

Technically, you don't have to worry about affordability. You are not required to provide insurance and so you're not at risk for penalties.

However, affordability is still important because it will impact your employee's ability to receive premium tax credits (PTC). Remember, if your ICHRA is affordable, employees will not be eligible for tax credits (PTC). If it's unaffordable, then they can choose.

Note: In this case, it's based on the employee's actual data when they go to the marketplace, not the safe harbors we use for ALEs. 

If you're concerned about impacting tax credits for your employees, let's talk-about-it! We have other calculators and methods we can help you use to design an ICHRA that'll optimize your spend and your employee's welfare.

How does the calculator work? What are the assumptions?

Our calculator pulls actual reference plan data (the lowest cost silver plan, LCSP) and calculates affordability numbers based on 3 available safe harbors (see FAQ below).

We assume employee-only coverage and ignore any dependents that might be involved. This is consistent with other safe harbor rules that employers can calculate affordability based on employee-only information.

Note: "Affordability" results do not necessarily have to drive ICHRA design. They are just a starting point!

Why is the calculator showing a result of $0?

We promise it's still working!

If your employee is relatively highly paid, it's possible the "Wages" or "Rate of Pay" safe harbor may show a result of $0. This technically means that your employee can purchase insurance on their own affordably without an HRA contribution.

Now does that mean you can offer a $0 or $1 ICHRA to satisfy the corporate mandate? According to our technical understanding, yes, but all of your employees will probably quit--so there's that to consider. We're still awaiting IRS guidance for this scenario.

What are the "Safe Harbors"?

The IRS recognizes that it may be difficult for an employer to collect all of the information needed to accurately determine affordability for each employee.

As a result, the IRS provides several "safe harbors" or assumptions that employers can make to determine affordability. For a complete list and examples, please see the "Affordability" section of our ICHRA Guide.

How does ICHRA affordability impact an employee's ability to get tax credits?

If an employee receives an "affordable" ICHRA, then that employee is not eligible for premium tax credits (PTC).

If an employee receives an "unaffordable" ICHRA, then the employee is allowed to either accept the HRA or opt-out of the HRA (one-time a year) and accept premium tax credits.

For additional information and examples, please see the Affordability Section of our ICHRA Guide.

Reminder: Applicable Large Employers (ALE) subject to the ACA's corporate mandate must provide an affordable HRA or face penalties for not providing affordable coverage.

Note: If an employer utilizes the safe harbors but the employee's actual information determines the HRA to be unaffordable, then the employer is not liable for penalties and the employee can still opt-out of the HRA to receive tax credits.

What happens if an ICHRA is not affordable for an employee?

If an employee receives an ICHRA allowance that is deemed "not affordable", then the employee may either:

  1. Accept the ICHRA allowance
  2. Opt-out of the ICHRA and receive a premium tax credit (PTC)

Employees are allowed to make this election once per plan year or when there are significant changes to the plan.

If the employer offering the unaffordable ICHRA is an applicable large employer (ALE), the employer may be liable for ACA penalties for not providing affordable coverage.

How can I learn more about ICHRA and affordability requirements?

We'd love to help!

A great resources is our ICHRA Guide. We even wrote a whole section on Affordability and provide some examples and references that can be helpful.

We'd also love to meet you! Feel free to email, chat, or schedule a call with us below. We'd love to know you and your exact (or your client's exact) situation to see how we can help!

Want to talk with one of our ICHRA design experts?

We'd love to get to know you. Please let us know how you prefer to get in touch.

One of us will be in touch!

We look forward to meeting you.

The Team
Want to learn more? Discover our ICHRA resources or get in touch.