On September 3, the Centers for Medicare & Medicaid Services (CMS) announced that ICHRA plans are now known as CHOICE Arrangements.
CHOICE, which stands for Custom Health Option and Individual Care Expense Arrangement, is a new name, not a new benefit. The individual coverage HRA works the same today as it did before the CMS announcement.
But even minor changes to employee health benefits can create uncertainty. Your clients will want to know what the rebrand means for their employees and how it affects their business. This short guide explains what you need to know to answer their questions with confidence and clarity.
The benefits model you know as ICHRA is now called a CHOICE Arrangement. The name has changed, but the mechanics are the same:
Employers provide tax-free dollars that eligible employees use to purchase individual health insurance.
Employees choose individual coverage based on their own needs.
Employers design and administer the arrangement according to federal requirements.
Even though the underlying rules remain unchanged, the rebrand is meaningful. CHOICE is easier to remember and reflects the benefit's core value: employers control the contribution, employees choose their coverage. The new name also gives benefits consultants a clear starting point when explaining how the model differs from traditional group insurance.
Employers who are already familiar with ICHRA simply need to understand that the name has changed. The branding is different, but the client experience is consistent. Your clients can expect to hear both ICHRA and CHOICE Arrangements in the short term as carriers, administrators, and benefits consultants adapt to the change.
When working with employers who are new to individual insurance, the rebrand is an opportunity to emphasize the advantages of offering choice.
Employees shop for insurance on the individual market and make their selection based on:
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Monthly premiums
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Prescription drug coverage
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Provider networks in their local area
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Deductibles and out-of-pocket costs
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Their family’s expected healthcare needs
If ICHRA was the right fit for your client, so is a CHOICE Arrangement.
There's no need to put client conversations on hold; you can keep moving forward with the strategies and cases you have in motion. Just make sure employers know about the recent change to avoid confusion.
It will take some time for the term ICHRA to disappear entirely; guides and other resources you share with employers during evaluation and implementation might not yet reflect the change. You should expect ICHRA and CHOICE Arrangements to coexist in conversations and industry materials during the transition.
The rebrand is a step in the right direction, and it provides benefits consultants with simpler language to introduce the model to clients. However, we believe more can be done to make CHOICE Arrangements a strong option for your clients and their employees.
Together with the HRA Council and other leading platform administrators, we're lobbying for changes that would break down the barriers to adoption you come up against every day.
Our proposed changes include:
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Reallocating tax credit dollars to small businesses that offer CHOICE Arrangement
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Fixing COBRA insurance for individuals with a CHOICE Arrangement
- Improving the program's reporting and notice requirements
Long-standing regulatory issues should also be addressed to solidify CHOICE Arrangements and lay the foundation for their long-term growth.
Benefits consultants see firsthand where CHOICE Arrangements work well for employers and what needs to be improved. At Take Command, we understand the importance of those insights, and we plan to work closely with our partners to advocate for what comes next with CHOICE Arrangements. Your voice needs to be heard.
Daniela Holloway is Senior Manager of Benefits Consultant Enablement at Take Command, where she helps benefits consultants build the knowledge, confidence, and strategy to bring CHOICE Arrangements (formerly known as ICHRA) into the right client conversations. With experience building and supporting ICHRA programs across the benefits industry, Daniela brings a consultant-first perspective to helping advisors evaluate individual coverage strategies, navigate a changing market, and turn emerging opportunities into practical solutions for employers.
