ICHRA Rule #1.
Must have an Individual Policy to receive reimbursements.
Participants in an ICHRA must be covered by individual health insurance plans. Policies purchased through Health Insurance Marketplaces (on-exchange plans) are reimbursable, as are those purchased elsewhere (off-exchange plans). Medicare Parts A, B, and C are eligible as well. It is also acceptable for an employee to be reimbursed for expenses as a non-primary policyholder of a family member’s individual policy.