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Franklin County reviews ICRA option, VEBA use and self-funding feasibility in benefits workshop
Summary
Commissioners heard two vendor presentations and discussed shifting county benefit design to an Individual Coverage Health Reimbursement Arrangement (ICRA)/ICHRA, the limited use of the county VEBA trust and a feasibility study for self-funding health coverage.
Franklin County commissioners and staff spent a workshop session on March 5 reviewing alternative employee-benefit strategies, including an individual health-care reimbursement arrangement (ICRA/ICHRA), options to let employees use accumulated VEBA funds for individual premiums, and a self-funding feasibility analysis.
Wes Harris and Marshall (H.W.L. presenters) introduced the ICRA concept, saying it gives employees flexibility to shop for individual Marketplace plans while receiving employer reimbursement. "What the ICRA is is it's an individual health care reimbursement plan," one presenter said, noting the proposal would allow employer contributions to be paid as cash-in-lieu and reimbursed for Marketplace premiums up to a specified amount.
Presenters emphasized two county-specific concerns: rapid cost growth in the county's VEBA contributions and limited current utilization of VEBA funds. H.W.L. staff described Franklin County’s VEBA trust as containing roughly $10 million and said current annual utilization of those VEBA balances was low relative to total contributions; presenters framed the ICRA as a way to let employees apply VEBA balances to premium costs and to control long-term county costs by replacing dual health/VEBA contributions with a single, more-flexible employer contribution.
Dan Fisher of HUB International, joined by HUB colleagues Brandon and Jamie, cautioned that switching to an ICRA structure would not automatically satisfy Affordable Care Act (ACA) affordability safe harbors. Fisher, a CPA and ICRA-certified advisor, said employer-provided dollars under an ICRA may be treated differently for ACA affordability calculations and recommended careful legal and benefits counsel. HUB also presented a preliminary feasibility comparison showing a self-funded unbundled model could produce material budget savings for the county versus fully insured renewal projections; presenters provided a stop-loss estimate and a draft feasibility figure showing potential savings at current enrollment levels, with a caveat that results depend on claims experience and bargaining-unit decisions.
Commissioners asked practical questions about enrollment, COBRA/continuation coverage, Medicare interactions for older employees and whether 800 monthly employer contributions would be sufficient to meet ACA minimum-value and affordability thresholds. Presenters answered that the feasibility study and broker analyses would calculate ACA compliance using the county census and the marketplace plan mix and that the county could set different contribution classes (for example, bargaining units, executives or full-family coverage) to protect employees with higher premiums.
Presenters also outlined self-funding strategies: stop-loss (individual and aggregate) to limit employer exposure, direct contracting with local providers to control facility pricing, pharmacy carve-outs and disease-management or dialysis carve-outs for high-cost chronic claims. HUB cautioned that self-funding is not a good fit in every case, that it requires state approval in Washington (Department of Enterprise Services filings) and adequate reserve planning, and that the county should avoid fragmenting broker engagement during market negotiations.
Next steps taken in the workshop: brokers will finalize a self-funding feasibility analysis (CIFA) and stop-loss/TPA soft quotes for the county to review. Commissioners were told two additional broker presentations (Alliant and Marsh McLennan) are scheduled for the following week. No formal resolution or vote to change the county's benefits structure was taken at the March 5 workshop; presenters and staff characterized the session as exploratory and asked for direction to proceed with the feasibility analysis.
Ending: Staff and broker teams will complete the feasibility analysis and return with refined estimates, stop-loss quotations and legal analysis of ACA effects before the county considers plan design or bargaining negotiations.
