This guidance closely tracks IRS Notice 2018-88 and provides that an ICHRA offers “affordable” coverage if the difference between the amount of the reimbursement available through the ICHRA and the cost of self-only coverage for the lowest cost silver plan available to the employee on the ACA Exchange (in other words, an employee’s out-of-pocket cost for coverage on the ACA Exchange after reimbursement from the ICHRA, if the employee purchases the lowest cost silver plan)… [read post]