Last reviewed October 2026

Is a CHOICE Arrangement the same thing as an ICHRA?

Short answer: Yes. CMS now calls the individual coverage HRA (ICHRA) a “CHOICE Arrangement.” Only the name changed; the federal rules for classes, notices, affordability and substantiation are the same.

The CMS employer overview says CHOICE Arrangements “were previously known as Individual Coverage Health Reimbursement Arrangements (ICHRAs).” The regulations that actually govern the benefit, 26 CFR 54.9802-4 (IRS) and 29 CFR 2590.702-2 (DOL), still use the term “individual coverage HRA,” and published documents such as the DOL model notice keep their original titles.

A bill that would write a “CHOICE Arrangement” into the tax code is a separate matter and is not law. Do not build any proposed tax credit or proposed rule change from that bill into a budget.

Employers, vendors and carriers will use both names for a while. Writing “ICHRA (CHOICE Arrangement)” in proposals and notices keeps an employer from thinking it is being sold a new product, and nothing already set up, including the 90-day notice cycle, has to be redone because of the rename.

Sources

Topic: ICHRAs