Health care industry insiders say that employers of all sizes
are beginning to take a serious look at moving some of their health benefits to
Individual Coverage Health Reimbursement Arrangements (ICHRAs) starting in
2022.
In July 2019, the Trump administration finalized new regulations
for ICHRAs, giving employers greater flexibility to reimburse qualifying
employees buying health insurance policies on the individual market.
While the new ICHRA regulations took effect starting in the 2020
plan year, adoption has been slow so far. That could be changing: a Nov. 16
survey by Willis Towers Watson of large, national employers found that 15% of
respondents are "planning to offer or considering offering ICHRAs to at
least some portion of… employees in 2022 or later."
Jason Karcher, an actuary at Milliman Inc., explains that, while
ICHRAs do offer employers a real advantage by reducing the administrative
burden of managing health benefits, it's not clear they save employers money.
"The individual market is frequently more expensive on a
benefit-for-benefit basis than what you find on the employer market,"
Karcher explains. "So if you're looking to offer something with value,
it's not like it's an excellent savings."
Ashraf Shehata, the national sector leader for health care and
life sciences at KPMG, says that the administrative question alone is driving
interest in ICHRA. While Shehata agrees that commercial employer plans tend to
get better deals on reimbursement, "the feeling is that the offsets to
that would be a reduction in administrative costs."
"I think people are looking for more ways to give consumers
choice in their health benefits," Shehata adds. "The only way to do
that today, in a more structured benefits model, will actually drive up your
administrative costs as an employer. So if you can forgo some of the tax
advantages, but you pick up a reduction of your administrative burden and you
empower the employees to select their own plans, that could be a very
interesting model."
Katherine Hempstead, senior policy adviser at the Robert Wood
Johnson Foundation, suggests that the incoming Biden administration's stated
intention to peg the benchmark for premium tax credits to the second-lowest
cost gold plan instead of the current silver benchmark would make ICHRAs much
more appealing to employers, as it would allow enrollees to more easily afford
lower-deductible plans.
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