Probably, yes. If your employer is offering an ICHRA benefit, and also providing a way for you to payroll deduct your portion of the premiums that aren't covered by the ICHRA, you'll need to enroll in an off-exchange plan in order to take advantage of the payroll deduction. Internal Revenue Code does not allow any sort of pre-tax payroll deduction for on-exchange premiums, but it does not prohibit pre-tax payroll deductions for off-exchange premiums. Employers that establish ICHRAs might offer the pre-tax payroll deduction as a way to reduce taxes for the employer and employee, and also as a means of ensuring that the employees' portion of the premiums are paid on time and that employees' coverage doesn't lapse due to lack of premium payments. But again, this benefit can only be offered to employees who are enrolled in off-exchange plans. So if you're offered an ICHRA benefit and a chance to payroll deduct your portion of the premiums, you'll want to consider off-exchange plans that are available in your area. You can use the ICHRA benefit for on-exchange or off-exchange plans, but you can only get the tax advantage of paying your premiums on a pre-tax basis if your plan is purchased outside the exchange.