ICHRA (as well as QSEHRA) is a reimbursement arrangement rather than an account. This means that employees will typically pay for insurance or medical care themselves and then file a reimbursement claim. Employers only pay out funds to employees when a claim is made and approved. While some employers may choose to setup separate bank accounts for tracking purposes, it is not required.

Read more about "What happens to unspent funds" at year end.