Enrollment and Opt-outs
To maintain eligibility for the ICHRA plan, employees must have coverage through an individual health plan. These include on-exchange or off-exchange coverage, Medicare Parts A and B, or Medicare Part C. Family members are also able to participate. As with typical state and federal enrollment rules, there is a short enrollment window that opens and closes. Outside that window, only certain life events can trigger a new enrollment window – things such as getting married, having a baby, and moving. As an employer, by offering ICHRA to your employees, you are creating another enrollment window that they can use to purchase a qualifying plan.
Annually, you will need to offer employees the chance to “opt-out” of the ICHRA plan, allowing them to claim their tax credits instead.