If I hire someone mid-year, do they have to wait until January to enroll?

No, new hires can enroll as soon as they become eligible, based on the employer’s established waiting period. ICHRA creates a Special Enrollment Period (SEP), allowing flexibility for mid-year hires. Most insurance carriers will require a copy of the ICHRA Initial Notice and the employee’s eligibility date to approve the SEP, so it’s important to provide this documentation promptly when helping employees enroll in coverage.