How to Pair Direct Primary Care with a CHOICE Arrangement in Florida

On September 3, 2026, CMS and the Small Business Administration renamed the Individual Coverage Health Reimbursement Arrangement to the CHOICE Arrangement, short for Custom Health Option and Individual Care Expense. The structure, tax treatment, and compliance rules carry over unchanged from ICHRA — this is a rename, not a redesign. But the new name has put individual coverage HRAs back on the radar for a lot of Florida business owners, and one of the most common questions we get from Orlando employers is whether a CHOICE Arrangement can be paired with Direct Primary Care.

The short answer is yes, but the two benefits work together rather than inside one another, and understanding that distinction matters if you want to set this up correctly. A CHOICE Arrangement is an employer-funded HRA that gives employees a fixed, tax-free dollar amount each month to buy their own individual health insurance instead of enrolling in a traditional group plan. Per CMS, any employer can offer one regardless of size, and employers set it up by choosing which of the ten permitted employee classes to offer it to, deciding whether to include spouses and dependents, picking a contribution strategy, and either self-administering the arrangement or working with a third-party administrator.

Contributions can vary by age within a 3-to-1 ratio and by family tier, but they must be offered on the same terms to everyone within a class. Employees then use that money to enroll in an ACA-compliant Marketplace plan, an off-Exchange individual plan, or Medicare Part A and B or Medicare Advantage. That coverage is what makes the CHOICE Arrangement work — it is the financial backstop for hospitalizations, surgeries, specialist care, and anything else that falls outside primary care.

Direct Primary Care fills the gap the CHOICE Arrangement was never designed to cover. DPC is a flat monthly membership, typically $50 to $150 in the Orlando area, that gives employees unlimited primary care visits, same-day appointments, and direct access to a physician by phone or text. Where the CHOICE Arrangement pays for the catastrophic side of care, DPC covers the everyday side — the sick visits, the chronic disease management, the annual physicals — at a fraction of what those visits cost billed through insurance.

Employers who pair the two are essentially building a two-part benefit: individual insurance for the big stuff, DPC for everything else. Here is the part that trips people up. CMS is clear that a CHOICE Arrangement requires the employee to be enrolled in qualifying individual health insurance or Medicare to participate — a DPC membership by itself does not satisfy that requirement, and it never has under ICHRA either.

You cannot fund a CHOICE Arrangement and let an employee use it solely for a DPC membership instead of buying insurance. The two benefits also cannot be stacked inside the same HRA for the same class of employees, since federal rules generally prevent offering more than one HRA type to one class at once. In practice, Orlando employers handle this by keeping the two benefits administratively separate: the CHOICE Arrangement funds the individual insurance plan, and DPC access is arranged alongside it — through a payroll deduction, a direct group rate with a local clinic, or a separate stipend outside the HRA structure.

There is a real financial reason to pair the two beyond convenience. As of January 1, 2026, a provision that took effect under the 2025 tax law clarified that a qualifying DPC Service Arrangement no longer disqualifies someone from HSA eligibility, as long as the monthly fee does not exceed $150 for an individual or $300 for a family, with those caps indexed for inflation after 2026. That means an employee who uses their CHOICE Arrangement dollars to buy an HSA-eligible high-deductible individual plan can then pay their DPC membership fee directly out of a Health Savings Account with pre-tax dollars.

For a Florida employee in the 22 percent bracket paying $90 a month for DPC, that is close to $240 a year in tax savings on the membership alone, on top of whatever the employer is already contributing through the CHOICE Arrangement. For Orlando and Central Florida employers, the practical setup looks like this. First, establish the CHOICE Arrangement itself — define your employee classes, set a contribution amount your budget supports, and decide whether to self-administer or bring in a TPA to handle compliance.

Second, help employees select an HSA-eligible individual plan through the Marketplace if you want the HSA-plus-DPC tax advantage to apply, since not every plan tier qualifies. Third, separately arrange DPC access for your team — many Orlando DPC clinics offer employer group rates that make this easy to bundle into open enrollment communications even though it is not funded through the HRA itself. Fourth, put both pieces in writing during enrollment so employees understand which benefit covers what: the CHOICE Arrangement is their insurance money, and DPC is their primary care membership, and the two are not interchangeable.

This combination is gaining traction in Florida specifically because it sidesteps the two biggest complaints employers have about group health insurance — unpredictable annual premium increases and employees who still can't get a same-day appointment when they're sick. A CHOICE Arrangement caps the employer's monthly cost at a fixed contribution instead of a renewal-driven premium, and DPC gives employees the access that a high-deductible individual plan alone never provides. If you are an Orlando employer evaluating a CHOICE Arrangement for next year's benefits, it is worth talking to a licensed benefits advisor about structuring the contribution and plan selection, and separately reaching out to local DPC clinics about group enrollment.

Browse our directory of Direct Primary Care clinics across Orlando and Central Florida to compare employer programs and pricing near your office.