Because your employer is offering an Individual Coverage HRA (ICHRA) to help pay for individual health insurance, the IRS applies an affordability test to determine whether you may also qualify for subsidies (premium tax credits) through the Health Insurance Marketplace.
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If the ICHRA offer is considered affordable under IRS guidelines (based on your household income and the cost of the lowest-cost Silver plan in your area, minus your employer’s ICHRA contribution), then you are not eligible to receive premium tax credits through the Marketplace.
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If the ICHRA is considered unaffordable, you may choose to decline (waive) the ICHRA and instead apply for a Marketplace plan with subsidies, if you otherwise qualify.
⚠️ Important: If you accept the ICHRA, you cannot receive Marketplace subsidies. If you decline the ICHRA, you may only qualify for subsidies if the ICHRA is deemed unaffordable by IRS rules.
Canceling your ICHRA-covered plan or waiving benefits in order to apply for Marketplace subsidies without meeting the IRS affordability exception may result in you being ineligible for those subsidies and could create unexpected tax consequences when you file your federal return.
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