2026 silver rates lookup table published for ICHRAs to determine affordability

Applicable Large Employers (ALEs) sponsoring an Individual Coverage Health Reimbursement Arrangement (ICHRA) must ensure each full-time employee’s offer is affordable based on the lowest-cost silver plan for the ZIP code where the employee resides or the ZIP code of the primary worksite to which they report. On December 11, 2025, the federal government published the updated table of 2026 lowest-cost silver rates for exchange plans, so ALEs may now determine affordability.

Who this applies to:

Employers sponsoring an ICHRA who employed on average 50 or more full-time and equivalent employees over calendar year 2025, making them an ALE for calendar year 2026. Employers under enough common ownership or control to be in a controlled group or affiliated service group must combine their employment counts.

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Compliance update brought to you by Benefit Compliance Solutions (BCS) in partnership with Nava Benefits. The information contained in this update, including any attachments, is presented solely in the capacity of Nava as compliance consultants. Nothing contained herein should be construed as tax or legal advice or opinion or used as a substitute for consultation with professional legal counsel. Nava is not authorized to practice law, is not an attorney or law firm, and is not rendering legal advice. Communications with Nava are not subject to attorney-client privilege.

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