Any employee designated as eligible by the employer can participate in an ICHRA. However, to receive reimbursements, employees must be enrolled in an ACA-compliant individual health insurance plan at the metal level (Bronze, Silver, Gold, or Platinum) or be enrolled in Medicare, including applicable Medicare Part A, B, Part C (Medicare Advantage), and Part D . Employers can define different classes of employees (e.g., full-time, part-time, seasonal) and must apply ICHRA offerings consistently within each class.
