Benafica is a health benefits and insurance company that helps employers offer flexible, tax-free health reimbursement plans instead of traditional group health insurance.
Affordability plays an important role in determining how much to contribute toward employees’ individual health coverage. For Applicable Large Employers (ALEs), it’s also a key part of meeting Affordable Care Act (ACA) requirements.
Affordability is measured against the lowest-cost silver plan in the employee’s area. If what’s left for the employee to pay for self-only coverage stays below a set percentage of their household income, the offer is affordable. That percentage is set by the IRS and changes every year: 9.96% of household income for 2026 and 10.22% for 2027.
Under the mandate, ALEs must:
The formula:
(Lowest-Cost Silver Plan monthly premium) – (Monthly ICHRA allowance) ≤ Affordability Threshold × (Employee Household Income ÷12)
An employee named Maria works for a company in St.Paul, MN. Her household income is
$48,000 per year. The lowest-cost silver plan in her rating area costs $520 per month.
If the employer’s ICHRA offers Maria $150/month, the ICHRA is affordable for her. If the
employer offers only $100/month, the ICHRA is unaffordable, and Maria could qualify for exchange subsidies.
The formula above requires knowledge of the employee’s household income — information that most employers do not have and cannot legally require employees to disclose.
To resolve this, the IRS created three affordability safe harbors that allow employers to
substitute known, employer-accessible data for household income.
The FPL safe harbor uses the federal poverty guideline for a one-person household as a proxy for employee income.
How it works: Coverage is deemed affordable if the employee’s monthly cost for the lowest-cost silver plan (after subtracting the ICHRA allowance) does not exceed the applicable affordability percentage of the one-person FPL divided by 12.
The Rate of Pay safe harbor calculates affordability based on the employee’s compensation at the beginning of the plan year, using a formula that accounts for hourly vs. salaried employees.
2026 example (employee earning $16/hr):
$16 × 130 × 9.96% = $207.17/month maximum employee contribution
2026 example (employee earning $3,500/month):
$3,500 × 9.96% = $348.60/month maximum employee contribution
The W-2 safe harbor uses the employee’s Box 1 wages from the prior year’s W-2 as the income proxy.
Affordability is determined by checking whether the employee’s annual cost for the lowest-cost silver plan (net of ICHRA allowance) does not exceed the affordability percentage of their W-2 income.
2026 W-2 safe harbor example:
An employee had Box 1 wages of $42,000 on their W-2. The employer offers an ICHRA allowance of $200/month, and the lowest-cost silver plan in the employee’s rating area costs $450/month.
If an ICHRA allowance doesn’t meet affordability thresholds, two things can happen:
An “affordable” ICHRA generally disqualifies employees from premium tax credits. This can sometimes create friction where employees had previously been receiving significant APTCs. If your allowance is generous enough to be affordable, but not enough to offset the premium, they could end up paying more than they were before.
Benafica recommends that employers review the lowest-cost silver plan premiums and APTC eligibility to ensure their ICHRA design is genuinely beneficial for all employee classes.
For employers with fewer than 50 full-time equivalent employees, the ACA employer mandate does not apply, and affordability rules are different. Smaller employers can often use a QSEHRA instead of an ICHRA, which carries its own IRS contribution caps but is subject to a different affordability framework.
If you are unsure whether your business qualifies as an ALE or whether ICHRA or QSEHRA is
the better fit, Benafica can help you evaluate your options.
Affordability compliance is not a one-time calculation. It must be revisited every plan year as the IRS adjusts the affordability percentage, silver plan premiums change, employees move between rating areas, and compensation levels shift.
At Benafica, affordability testing is built into our proposal process, so your ICHRA is designed to be compliant before it launches. For every proposal, we:
Our team works alongside HR professionals, CFOs, and benefits consultants to ensure that ICHRA plans are designed compliantly from the start.
An ICHRA is affordable if the employee’s cost for the lowest-cost silver plan (self-only) in their rating area, after subtracting the employer’s monthly allowance, doesn’t exceed a set percentage of their income. The IRS adjusts that percentage each year.
Applicable large employers (50+ full-time equivalent employees) that don’t offer affordable coverage may owe penalties under the ACA employer mandate. Affordability also determines whether an employee can claim a Premium Tax Credit instead of using the ICHRA.
We identify each employee’s rating area, find the lowest-cost silver plan premium for their age, and compare the employee’s required contribution to the IRS threshold using one of the IRS safe harbors.
The W-2 wages, rate of pay, and federal poverty line safe harbors. We apply the appropriate one to each employee class.
The employer mandate applies only to ALEs. Smaller employers still need to consider affordability because it affects whether employees can claim Premium Tax Credits.
Every plan year, since the IRS percentage, silver plan premiums, rating areas, and compensation can all change.
Yes, we test affordability for each employee class and recommend allowance levels that meet the standard.
Send us your census and your counties and we’ll run the affordability test at three allowance levels, so you can see exactly where the line sits before you commit.
Benafica is an ICHRA and QSEHRA administration company and Third-Party Administrator (TPA) based in St. Paul, MN. This content is provided for educational purposes and does not constitute legal or tax advice. IRS penalty amounts and affordability percentages are subject to annual adjustment. Consult a qualified benefits advisor or legal counsel for guidance specific to your organization.