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Acceptable Use Policy

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Acceptable Use Policy

Last updated: August 21, 2025

This Acceptable Use Policy applies to your use of Services provided by Thatch. Employer Restrictions, which are governed by our financial partners and card networks, apply to employers who offer benefits to their employees using Thatch. Employee Restrictions, which are governed by benefits and tax rules, apply to employees who participate in benefits using Thatch. Any terms used in this Acceptable Use Policy have the meanings set forth in the Platform Agreement. If you have questions about how these lists apply to you, please contact us at support@thatch.ai.

By registering for Thatch, you agree to use the Services consistent with this Acceptable Use Policy.

1. Employer Restrictions

Unsupported Businesses

Thatch does not administer ICHRAs on behalf of employers that sell, produce, or provide services related to:

Illegal drugs or substances Cannabis or cannabis-related products/services

Counterfeit, pirated, or stolen goods

Gambling operations and casinos

Adult content and products

Virtual currencies and digital assets

Firearms, explosives, and hazardous materials

Businesses transacting with entities in sanctioned countries

2. Employee Restrictions

Unsupported Individuals

The following individuals are ineligible to participate in ICHRAs:

Independent contractors

Employees who do not belong to a class offered an ICHRA by their employer

Employees not enrolled in qualifying individual health insurance

Employees using Premium Tax Credits (PTCs) to purchase their individual coverage from an Exchange

Employees that own more than 2% of an S-Corporation (or a business taxed as an S-Corporation) sponsoring the ICHRA

Any other individuals prohibited from participating by applicable regulations

Unsupported Expenses

The following expenses ineligible for reimbursement under an ICHRA:

Expenses incurred before the beginning of the Member’s participation in the Employer’s benefits

Expenses reimbursed by another another plan

Food, vitamins, or dietary supplements

Gym memberships that are not purchased to treat a particular medical condition

Non-medical cosmetic products or procedures

Personal use items and household supplies

Prepayment for products and services

Employers determine whether their ICHRA reimburses for Insurance Plans only, or for both Insurance Plans and Qualified Medical Expenses. Eligible reimbursements are specified in Healthcare Notices. Members participating in benefits that reimburse Qualified Medical Expenses can request reimbursement for any medical expense under Section 213(d) of the Internal Revenue Code, as detailed in IRS Publications 502, IRS Publication 969, the CARES Act, and other applicable guidance documents and notices. Thatch will determine whether an expense qualifies as a Qualified Medical Expense in its sole discretion.

Thatch may require a letter of medical necessity (“Letter of Medical Necessity”) from a licensed medical professional before reimbursing expenses not expressly authorized. A Letter of Medical Necessity must specify the expense and that the expense is for treating a particular medical condition. A Letter of Medical Necessity recommending a purchase for general health and not a particular medical condition will not be sufficient.

Thatch may modify this Acceptable Use Policy at any time.

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