Managing Health Insurance Coverage under ICHRA
Employees using an Individual Coverage Health Reimbursement Arrangement (ICHRA) often encounter various situations that require specific actions to maintain or update their health insurance coverage. This guide outlines the common scenarios employees might face and steps to manage coverage.
Proof of Coverage Requirements
To be eligible for tax-free reimbursement under an ICHRA, employees must have an individual market health insurance policy. The policy must either be in the employee's name or include them as a covered individual. Specific considerations include:
Spouse's Health Plan: If the employee is covered under their spouse's plan, the employee must be listed as a covered individual. - Steps to Resolve: - Provide proof of coverage, like policy documents or ID cards, showing the employee as a covered individual. Submit these to Take Command for approval. - If the employee is not listed, update the health plan during a special enrollment period and resubmit documentation reflecting the update.
Shared Plan Proof of Coverage: Proof of Coverage (POC) must be submitted individually for each person, even if they are on the same health plan. Reviews are conducted per individual, and one person’s documentation cannot be used to verify another.
Termination of Employment: Managing Coverage and Reimbursements
When employment ends and the employee's ICHRA-covered health plan continues post-termination:
The individual owns the health insurance policy and can maintain it by paying premiums directly to the insurance carrier. - Employees may also cancel their coverage anytime.
ICHRA allowances for the entire month remain available if the employee was active at any point during the month.
Employees have 90-day access to the Take Command portal post-termination to submit any eligible expenses incurred while covered. During this period, they will appear under the 'Suspended' section of the employer’s roster. Note that Take Command does not notify employees about their options for continuing coverage—it is the employee’s responsibility to manage this.
Switching to a Spouse’s Plan
If an employee transitions from an individual ICHRA plan to a spouse’s health plan:
Provide the last day of the individual coverage to Take Command. The plan will then be marked as ended in the system, and the employee's profile will be updated.
Benefits can be waived instead of terminating the entire account, helping maintain accurate employer reporting and statements.
Waiver Submissions in a New Portal
When transitioning to a new portal for coverage management or documentation submission, previous waivers for employees covered under a spouse's plan must be re-submitted.
Add the employee to the new portal and submit a waiver request if coverage under the spouse's plan is still active.
Related Topics
Special Enrollment Periods & Eligibility
Transitioning Between Health Insurance Plans
Submitting Eligible Expenses under ICHRA
For further help, contact Take Command Support or refer to the detailed user guide in your Take Command portal.