This model turns the employer into the master architect of a benefits supply chain — leveraging individual market carriers as infrastructure, not vendors.
By Michael King -ICHRA Wholesale Specialist
No stop-loss. No lasering. No underwriting. No RxDC. Just control, cost certainty, and compliance.
Want to “self-fund” health benefits without traditional headaches? Meet the Copper Plan ICHRA + Section 213(d) Expense HRA strategy — a next-gen model that transforms the individual market into a de facto self-insured health plan, backed by ACA carriers, not overpriced stop-loss contracts.
Here’s the playbook:
✅ Copper Plan – Employees buy ultra-low-premium individual coverage (AV ~50%) via the ACA exchange. Catastrophic coverage with $9,000–$19,000 OOPMs.
✅ ICHRA – Employers reimburse premiums tax-free. Fully controlled, scalable by employee class. ALE-compliant.
✅ Section 213 HRA – Reimburse OOP costs tax-free. Pay-as-you-go, capped exposure. Consider the difference: $19K max per family vs. $400K+ under traditional self-funding.
Why it works for large groups (100+):
⚙️ The front-end: You “self-fund” expected costs (premiums + OOP) through predictable, budgeted reimbursements.
🔒 The back-end: ACA carriers assume all catastrophic risk — no exclusions, no renewals denied, no lasers.
🎯 Bonus wins:
• Skip RxDC, gag clause attestations, and CAA burdens
• No group underwriting or rate shocks
• No TPA dramas or reserve funding
• Maximum ERISA control, minimum admin
• ACA-compliant and ERISA-covered — but your liability is capped
This model turns the employer into the master architect of a benefits supply chain — leveraging individual market carriers as infrastructure, not vendors.
🧠 Want your CFO to sleep better? Show them how this caps exposure while enriching benefits.
