EMPLOYER INTAKE CHECKLIST · NAMING UPDATED SEPTEMBER 9, 2026
Short answer: The best CHOICE discovery questions cover four areas: why the employer is considering change, who must be served and where they live or work, what current individual coverage and employer contributions could mean for employees, and who will own notices, enrollment, substantiation, reimbursements, privacy, and service. The answers determine whether CHOICE deserves a formal analysis; they do not by themselves prove that the arrangement is compliant or a good fit.
Official sources: CMS: Employer Initiatives — CHOICE Arrangements · CMS: Health Reimbursement Arrangements and employer LCSP resources · U.S. Department of Labor: FAQs on New Health Coverage Options · U.S. Department of Labor: Individual Coverage HRA Model Notice
Start a conversation about CHOICE Arrangements (formerly ICHRAs) with the employer’s business problem and complete workforce facts. These questions organize the first discussion and show what must be validated next.
By NHP University Editorial Team · Review method · CMS naming reviewed September 9, 2026; technical sources reviewed August 14, 2026
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Work through 12 employer questions, an evidence map, red flags, and a next-step matrix before recommending a formal analysis.
Use non-sensitive business facts only. Do not enter names, dates of birth, Social Security numbers, health information, or census data.
CURRENT CMS TERMINOLOGY
CMS now uses CHOICE Arrangements for the arrangements formerly called ICHRAs. This naming update does not itself change the requirements discussed in this guide.
Sources for this section: CMS: Employer Initiatives — CHOICE Arrangements
PART 1 · DEFINE THE BUSINESS PROBLEM
Ask for the concrete issue: renewal volatility, employer budget, participation, network gaps, recruiting, distributed employees, contribution equity, administration, or something else. Record how success will be measured.
Document group plans, employer contributions, eligibility, waiting periods, participation, COBRA or continuation processes, renewal date, current vendors, and any arrangements offered through related employers.
Identify budget ceiling, provider or prescription needs, employee contribution targets, recruitment commitments, collective-bargaining terms, plan-year timing, and leadership expectations.
Agree whether the analysis will include the current plan, alternative group proposals, CHOICE, QSEHRA if the employer may be eligible, or other supported options. Avoid designing the evaluation to make one result inevitable.
Sources for this section: U.S. Department of Labor: FAQs on New Health Coverage Options
PART 2 · UNDERSTAND WHO NEEDS COVERAGE
Gather accurate work and home locations at the level needed for rating areas, plan availability, networks, and applicable state rules. A headquarters ZIP code is not a distributed-workforce census.
Document full-time, part-time, seasonal, salaried, hourly, union, temporary-staffing, waiting-period, and other relevant facts without assuming they automatically form permitted CHOICE classes.
Review current premiums, carriers, networks, metal levels, plan designs, service areas, and enrollment pathways for the employees’ real locations. Flag areas with limited or unsuitable choices.
Identify Medicare eligibility, Marketplace premium tax credits, dependent coverage, provider and prescription needs, midyear enrollment, and other household facts that can change the employee experience.
Sources for this section: CMS: Health Reimbursement Arrangements and employer LCSP resources · IRS: Questions and Answers on the Premium Tax Credit · U.S. Department of Labor: FAQs on New Health Coverage Options
PART 3 · TEST THE DESIGN AND OPERATING MODEL
Clarify budget, desired employee share, family strategy, whether age or dependent variation is being considered, and how the employer will evaluate affordability and future increases.
Name the qualified party who will validate permitted classes, same-class terms, any minimum-class-size rule, nondiscrimination issues, waiting periods, and interaction with other offers.
Assign plan documents, required notices, employee communication, enrollment support, opt-outs, coverage substantiation, reimbursements, payroll coordination, privacy, records, and carrier or Marketplace handoffs.
Define support channels, issue escalation, eligibility changes, qualifying events, failed substantiation, reimbursement timing, annual re-enrollment, contribution review, and renewal decision ownership.
Sources for this section: CMS: Health Reimbursement Arrangements and employer LCSP resources · IRS: Questions and Answers on the Premium Tax Credit · U.S. Department of Labor: FAQs on New Health Coverage Options · U.S. Department of Labor: Individual Coverage HRA Model Notice · U.S. Department of Labor: Individual Coverage HRA Model Attestations
TURN THE CONVERSATION INTO EVIDENCE
Collect only what is needed, use secure methods for sensitive data, and agree who may access it. The first call should create a clean request list rather than invite personal information into email.
| Input | What to request | What it helps validate |
|---|---|---|
| Current benefit materials | Renewal, summary materials, contribution schedule, eligibility rules, participation, and service issues | The baseline cost, coverage, and employee experience |
| Workforce census | Employee locations, eligibility groups, coverage tiers, and only the demographic inputs needed for analysis | Plan-market availability, contribution modeling, and potential class questions |
| Employer structure | Related entities, employee counts, full-time equivalents, current offers, and collective-bargaining facts | Employer obligations, QSEHRA eligibility, and controlled-group questions for qualified review |
| Decision criteria | Budget range, target employee outcomes, network or prescription priorities, timing, and leadership approvals | Whether each alternative addresses the employer’s actual problem |
| Operating plan | Proposed administrator, broker, legal and tax support, payroll owner, communication owner, and service standards | Whether the employer can launch and sustain the arrangement responsibly |
Sources for this section: CMS: Health Reimbursement Arrangements and employer LCSP resources · U.S. Department of Labor: FAQs on New Health Coverage Options
LISTEN FOR WHAT CHANGES THE ANALYSIS
| What you hear | Responsible next step | Do not assume |
|---|---|---|
| Employees are spread across many states | Check plan availability, networks, rates, enrollment paths, and producer authority by location | That geographic spread automatically makes CHOICE better |
| The group renewal increased sharply | Compare the full renewal with current individual-market outcomes and sustainable contributions | Employer savings will equal employee savings |
| Leadership wants different benefits for different workers | Validate whether the proposed distinctions are permitted classes and whether minimum class size applies | Any business label can become a CHOICE class |
| Employees currently receive Marketplace tax credits | Model current affordability and premium-tax-credit effects with current official guidance | Employees can accept CHOICE and keep the same credit |
| The employer wants a quick launch | Build a realistic timeline for plan design, notice, enrollment, substantiation, payroll, and support | A reimbursement amount and vendor signup complete implementation |
| No one owns employee questions | Define the administrator, broker, employer, carrier, Marketplace, and specialist escalation roles | Employees will navigate the transition without structured support |
Sources for this section: CMS: Health Reimbursement Arrangements and employer LCSP resources · IRS: Questions and Answers on the Premium Tax Credit · U.S. Department of Labor: FAQs on New Health Coverage Options · U.S. Department of Labor: Individual Coverage HRA Model Notice
KNOW WHEN TO PAUSE
Do not model employee outcomes from a headquarters location, outdated roster, or missing eligibility and coverage-tier data.
Pause when the employer or seller wants CHOICE regardless of market, employee, affordability, class, or administration findings.
Do not improvise plan documents, tax conclusions, ERISA positions, payroll treatment, or legal interpretations without qualified support.
A design is not ready if no one owns notice, plan shopping, enrollment, substantiation, reimbursement questions, and escalations.
Sources for this section: U.S. Department of Labor: FAQs on New Health Coverage Options · U.S. Department of Labor: Individual Coverage HRA Model Notice · U.S. Department of Labor: Individual Coverage HRA Model Attestations
A CHECKLIST IS NOT A COMPLIANCE DETERMINATION
This checklist and any uPPo course are educational tools. Completing them does not make an employer eligible, approve an employee class, calculate affordability, create plan documents, satisfy notice or substantiation duties, or replace current advice from licensed and qualified professionals.
uPPo is a private NHP University education credential. It is not issued, required, or endorsed by CMS, the IRS, the Department of Labor, a state insurance department, a carrier, or an exchange. It does not grant an insurance license or guarantee leads, clients, sales, commissions, or income.
Sources for this section: CMS: Health Reimbursement Arrangements and employer LCSP resources · IRS: Questions and Answers on the Premium Tax Credit · U.S. Department of Labor: FAQs on New Health Coverage Options · U.S. Department of Labor: Individual Coverage HRA Model Notice · U.S. Department of Labor: Individual Coverage HRA Model Attestations
COMMON QUESTIONS
Ask what specific business problem the employer wants to solve and how success will be measured. That answer creates criteria for comparing the current plan, group alternatives, CHOICE, and any other viable option.
Typically the analysis needs accurate employee locations, eligibility groups, coverage tiers, and only the demographic inputs needed for current premiums and contribution modeling. Use secure collection, limit access, and involve qualified partners for privacy and data-handling requirements.
A headquarters ZIP code is usually too weak for a distributed workforce. Individual plan availability, premiums, and networks vary by location, so analysis should use the employees’ meaningful locations and current plan-year data.
No. It organizes facts and open questions. The employer’s final design, employee classes, affordability work, notices, plan documents, substantiation, tax treatment, and operations should be reviewed by the licensed and qualified parties responsible for them.
No. uPPo documents completion of a private educational curriculum. It is not a state insurance license, carrier appointment, administrator contract, government certification, or authorization to provide legal, tax, ERISA, or compliance advice.
BUILD A REPEATABLE, RESPONSIBLE CONVERSATION
Explore uPPo education after confirming the license and professional support your role requires. uPPo is a private educational program, not a government credential, plan approval, or guarantee of clients or income.
This guide is educational and does not guarantee a license, job, appointment, client, income, or regulatory outcome. Requirements and programs change; confirm current rules with the responsible regulator, agency, employer, exchange, or carrier.
Published 2026-08-14. Last modified 2026-09-09. CMS naming reviewed September 9, 2026; technical sources reviewed August 14, 2026.
September 9 naming update: adopted CMS’s CHOICE Arrangements name (formerly ICHRAs) and preserved existing links. Policy-source review remains August 14, 2026; this update does not represent a full regulatory review.
See the editorial and corrections policy.
