The short answer Idaho runs its own exchange (Your Health Idaho), expanded Medicaid in 2020, and has no state benefits mandates.
What Idaho requires
Idaho
Exchange. Idaho runs its own state-based exchange, Your Health Idaho - the first state-built exchange in the country. Note Idaho's open enrollment runs earlier than most states (October 15 - December 15).
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Medicaid expansion. Idaho expanded Medicaid effective January 2020 after a ballot initiative; adults to 138% FPL qualify.
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No state employer benefit mandates. Idaho has no state individual mandate or 1095 reporting, no auto-IRA program, and no paid family leave program.
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From Vitable
See what you owe in case of an audit.
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The federal baseline (applies in every state)
Federal
ALE threshold & counting caregivers. The ACA employer mandate applies to Applicable Large Employers (ALEs) with 50+ full-time equivalent employees (30+ hrs/week or 130 hrs/month). Home care agencies with variable-hour caregivers can use the IRS look-back measurement method (3-12 month measurement period plus a stability period) to determine which caregivers must be treated as full-time and offered coverage.
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2026 employer mandate penalties. For 2026, the Section 4980H(a) penalty (no offer of minimum essential coverage to 95% of full-time staff) is $3,340 per full-time employee minus the first 30; the 4980H(b) penalty (coverage unaffordable or not minimum value) is $5,010 per full-time employee who gets subsidized exchange coverage (Rev. Proc. 2025-26).
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2026 affordability percentage. Coverage is affordable in 2026 if the employee's self-only contribution does not exceed 9.96% of household income (up from 9.02% in 2025), per Rev. Proc. 2025-25. Employers may use the W-2, rate-of-pay, or federal poverty line safe harbors in place of household income.
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2026 FPL safe harbor. A 2026 plan automatically satisfies the federal poverty line affordability safe harbor if the lowest-cost self-only contribution is no more than $129.89/month ($15,650 mainland FPL x 9.96% / 12). Alaska and Hawaii use higher FPL figures (about $162.26 and $149.31/month respectively).
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1095-C deadlines (2025 forms filed in 2026). ALEs must furnish Forms 1095-C to employees by March 2, 2026, or use the alternative method under the Paperwork Burden Reduction Act: post a clear website notice and furnish a copy within 30 days of request. E-filing of Forms 1094-C/1095-C with the IRS is due March 31, 2026, and e-filing is mandatory for employers filing 10 or more returns.
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ICHRA as a compliance option. An Individual Coverage HRA (ICHRA) lets agencies reimburse caregivers' individual-market premiums tax-free and counts as an offer of coverage under 4980H. An ICHRA is affordable if the employee's cost for the lowest-cost self-only silver plan, minus the HRA allowance, stays within the 9.96% affordability threshold; employee classes (e.g., field caregivers vs. office staff) can receive different allowances.
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Enhanced premium tax credits expired 12/31/2025. The ARPA/IRA enhanced premium tax credits expired December 31, 2025, restoring the 400% FPL subsidy cliff. KFF estimates average subsidized marketplace premium payments more than doubled (about +114%) for 2026, making employer-sponsored coverage and ICHRAs more attractive to caregivers - and increasing the chance that full-time employees seek subsidized exchange coverage that triggers 4980H penalties for non-offering agencies.
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