S2875-119

In Committee

CHOICE Act

119th Congress Introduced Sep 18, 2025

Summary

What This Bill Does

The bill creates the CHOICE arrangement (Custom Health Option and Individual Care Expense arrangement) as a new HRA type under the IRC, amends Section 125(f)(3) IRC to allow employees in CHOICE arrangements to use cafeteria plan (pre-tax) funds for ACA exchange insurance. Removes the current barrier, and adds new Section 45BB to IRC creating employer tax credit for eligible small employers establishing CHOICE arrangements. $100/month per enrolled employee in year 1, $50/month in year 2. 2-year credit period. CPI. It relies on exemptions, tax credits, compliance mandates, and reporting requirements. The main policy areas are Finance, Healthcare, and Labor.

Who Benefits and How

ACA exchange marketplaces could gain revenue opportunities, Small employers establishing CHOICE arrangements could see lower costs, and Small employers (non-applicable large employers) could see lower costs.

Who Bears the Burden and How

Federal government (tax expenditure) could lose revenue opportunities, Federal government (reduced tax revenue) could lose revenue opportunities, and Federal government (tax revenue) could lose revenue opportunities.

Key Provisions

  • Creates the CHOICE arrangement (Custom Health Option and Individual Care Expense arrangement) as a new HRA type under the IRC.
  • Amends Section 125(f)(3) IRC to allow employees in CHOICE arrangements to use cafeteria plan (pre-tax) funds for ACA exchange insurance. Removes the current barrier.
  • Adds new Section 45BB to IRC creating employer tax credit for eligible small employers establishing CHOICE arrangements. $100/month per enrolled employee in year 1, $50/month in year 2. 2-year credit period. CPI...
  • Creates inserted text of new Section 45BB IRC: $100/month (year 1) and $50/month (year 2) per-employee credit for eligible small employers maintaining CHOICE arrangements.

Evidence Chain:

This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.

At a Glance

What This Bill Does

The bill creates the CHOICE arrangement (Custom Health Option and Individual Care Expense arrangement) as a new HRA type under the IRC, amends Section 125(f)(3) IRC to allow employees in CHOICE arrangements to use cafeteria plan (pre-tax) funds for ACA exchange insurance. Removes the current barrier, and adds new Section 45BB to IRC creating employer tax credit for eligible small employers establishing CHOICE arrangements. $100/month per enrolled employee in year 1, $50/month in year 2. 2-year credit period. CPI.

Key Policy Areas

Finance, Healthcare, Labor

Primary Purpose

The bill creates the CHOICE arrangement (Custom Health Option and Individual Care Expense arrangement) as a new HRA type under the IRC, amends Section 125(f)(3) IRC to allow employees in CHOICE arrangements to use cafeteria plan (pre-tax) funds for ACA exchange insurance. Removes the current barrier, and adds new Section 45BB to IRC creating employer tax credit for eligible small employers establishing CHOICE arrangements. $100/month per enrolled employee in year 1, $50/month in year 2. 2-year credit period. CPI.

Policy Domains

Finance Healthcare Labor

CHOICE Act - Health Reimbursement Arrangements

Identified Gains
  • ACA exchange marketplaces
  • Small employers establishing CHOICE arrangements
  • Small employers (non-applicable large employers)
  • Employees in CHOICE arrangements
  • Individual health insurance market issuers
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
ACA exchange marketplaces: ,
Employees in CHOICE arrangements:
Individual health insurance market issuers:
Small employers (non-applicable large employers):
Small employers establishing CHOICE arrangements:
Identified Costs
  • Federal government (tax expenditure)
  • Federal government (reduced tax revenue)
  • Federal government (tax revenue)
  • Traditional group health insurance providers
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
Federal government (tax revenue):
Federal government (tax expenditure):
Federal government (reduced tax revenue):
Traditional group health insurance providers:

Legislative Progress

In Committee
Introduced Committee Passed
Sep 18, 2025

Mr. Sheehy introduced the following bill; which was read twice …

Sep 18, 2025

Read twice and referred to the Committee on Finance.

Sep 18, 2025

Introduced in Senate

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Financial Services
5 mentions across 3 clauses
+4 positive -1 negative

ACA exchange marketplaces, Individual health insurance market, Individual health insurance market issuers

Positive-direction: ACA exchange marketplaces, Individual health insurance market, Individual health insurance market issuers

Negative-direction: Traditional group health insurance providers

Government
3 mentions across 3 clauses
-3 negative

Federal government (reduced tax revenue), Federal government (tax expenditure), Federal government (tax revenue)

Small Business
2 mentions across 2 clauses
+2 positive

Small employers (non-applicable large employers), Small employers establishing CHOICE arrangements

Labor
2 mentions across 2 clauses
+2 positive

Employees in CHOICE arrangements, Employees of participating employers

Business
2 mentions across 1 clause
+1 positive

Employers offering the CHOICE arrangement, Small and mid-size employers

4/5
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Finance Healthcare Labor
Actor Mappings
"the_secretary"
→ Secretary of the Treasury

Key Definitions

Terms defined in this bill

4 terms
"credit period" §sec_4_credit_period

The first 2 one-year periods beginning with the month during which the employer first establishes a CHOICE arrangement

"specified class of employee" §sec_2_specified_class

Any of the following: full-time employees, part-time employees, salaried employees, non-salaried employees, employees in the same rating area, collective bargaining unit employees

"eligible employer" §sec_4_eligible_employer

An employer who is not an applicable large employer for the calendar year under section 4980H

"custom health option and individual care expense arrangement" §sec_2_choice_arrangement

A health reimbursement arrangement funded solely by employer contributions to provide payments or reimbursements for medical care subject to a maximum fixed dollar amount

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology