ICHRA does not require a minimum employee participation rate, meaning employers can offer the benefit even if only one employee chooses to enroll.
Do ICHRA plans require minimum participation?
No minimum participation is required
Employers can offer an ICHRA regardless of how many employees choose to participate.
This means:
✔ You can offer ICHRA to your entire workforce
✔ You can offer it to a subset of employees
✔ Employees are not required to enroll for the plan to remain valid
Even if only a single employee participates, the ICHRA remains fully compliant.
How ICHRA differs from traditional group health plans
ICHRA removes participation thresholds
Unlike traditional group health insurance:
Group plans often require minimum participation rates (e.g., a percentage of eligible employees)
ICHRA has no such requirement
This gives employers flexibility to:
Offer benefits without meeting enrollment thresholds
Scale benefits gradually
Combine ICHRA with other benefit strategies
When do “minimum class size” rules apply?
Only in specific plan designs involving employee classes
While there is no participation minimum, some employers using employee classes may need to meet minimum class size rules in limited cases.
This applies only when:
An employer offers a traditional group health plan to one class
AND offers ICHRA to another class
In those cases:
Certain employee class groups must meet minimum size thresholds based on total workforce size
If all employees are offered ICHRA uniformly, these class size rules do not apply.
Why ICHRA has no participation requirement
The design is individual-based, not group-based
ICHRA is structured so that:
Each employee chooses their own individual health insurance plan
Employers reimburse employees rather than sponsoring a shared group plan
Participation is optional at the employee level
Because of this structure:
No minimum enrollment is needed for compliance
Each participant is evaluated individually for eligibility
What employers should consider instead of participation rates
Focus on eligibility and affordability compliance
Even though participation is not required, employers must ensure:
Employees offered ICHRA have access to qualifying individual coverage
Reimbursements are only issued for eligible plans
Required notices and documentation are provided
Participation does not affect compliance—but eligibility does.