The ICHRA Employer Lowest Cost Silver Plan Premium Look-Up Table is published by the Centers for Medicare & Medicaid Services (CMS) to help employers determine whether an Individual Coverage Health Reimbursement Arrangement (ICHRA) they offer is considered “affordable” under ACA rules.
The Lookup Table contains the lowest cost silver plan premiums for individual Marketplace plans (qualified health plans) available in specific geographic areas. Silver plans are used because they are the benchmark for the ACA to ensure affordability and are the basis for calculating premium tax credits.
The table is intended for use with plans offered through Federally-facilitated Exchanges (FFEs) and State-based Exchanges on the Federal platform (SBE-FPs).
This is important because:
- Applicable large employers (employers with 50 or more full-time equivalent employees) must offer affordable coverage or potentially face a penalty under the ACA’s employer mandate. The affordability test uses the cost of the Lowest-Cost Silver Plan (LCSP) in an employee’s area as a benchmark.
- Employers can use the Look-Up Table to compare their ICHRA allowances against LCSP premium data by geographic location (including differences by age or rating area).
- If the employer’s contribution via the ICHRA, when subtracted from the LCSP cost, results in an employee contribution that does not exceed the affordability threshold (a percentage of income set by IRS rules for that plan year), the coverage is considered affordable.
Employer Considerations
There are several important employer considerations when using the Look-Up Table for the 2026 plan year, especially for ALEs trying to stay compliant with the ACA employer mandate.
- CMS’s Lowest Cost Silver Plan (LCSP) Look-Up Table is an approved safe harbor for determining the applicable benchmark premium for ICHRA affordability. Using the table correctly helps avoid penalties.
- If the employee’s required contribution exceeds the applicable IRS affordability threshold (as measured against household income or an employer affordability safe harbor), the ICHRA is unaffordable for that employee and may trigger §4980H(b) penalty exposure if the employee receives a premium tax credit.
- Employees must be informed whether the ICHRA is considered affordable as affordability affects eligibility for premium tax credits.
- To be ready for possible IRS audits, employers should retain the LCSP table version used, the ZIP code or rating area logic data, employee age assumptions, affordability calculations, and contribution schedules.
