"The ICHRA does not move the responsibility back fully to the employee alone, but instead provides an employer established account which the employee may access for medical expenses, including health insurance premiums, provided the individual provides proof they have purchased health insurance. If considered just as an account without consideration of all of the governing laws, it sounds like a way to place a dollar limit on healthcare costs for each employee; however, ... the preamble to the final regulations demonstrate the complex rules ... and the guidance still needed."

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