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ICHRA: How employees manage their health insurance coverage in different scenarios

This article is for employees enrolled in an Individual Coverage Health Reimbursement Arrangement (ICHRA) through Take Command Health’s HRA Hub platform.

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Written by Mel Vazquez-Martinez

Employees manage their ICHRA health insurance by maintaining an eligible individual (or Medicare) plan, keeping proof of coverage up to date, and updating their status in HRA Hub whenever their coverage, employment, or household situation changes.

Core requirement for all employees in an ICHRA

You must have qualifying coverage to stay eligible.

Eligibility may also depend on employer-defined classes, such as full-time, part-time, or geographic location. Employers may exclude certain classes, such as part-time employees, from eligibility, and this exclusion must be applied consistently across the class.

To participate in an ICHRA, you must have:

  • An ACA-compliant individual health insurance plan, OR

  • Medicare (Part A and B or Medicare Advantage)

You must also:

  • Submit proof of coverage

  • Keep coverage active and current

  • Update changes immediately in HRA Hub

If you do not maintain qualifying coverage:

  • ❌ You become ineligible for reimbursements

  • ❌ Claims may be paused or denied

Common scenarios and what employees should do


Scenario 1: You enroll in a new individual health insurance plan

If you switch or start a new plan:

  1. Enroll in an ACA-compliant individual health plan

  2. Update your plan details in HRA Hub

  3. Upload new proof of coverage showing:

    • Your name

    • Carrier and plan

    • Active coverage dates

  4. Set up or update recurring premium reimbursement (if applicable)

Your reimbursement eligibility resumes once coverage is verified.


Scenario 2: You move to a spouse’s employer plan

If you switch to a spouse’s group health plan: A spouse starting a new job with insurance does not automatically qualify as a life event unless it results in the loss of your current coverage or changes your eligibility. For example, involuntary loss of minimum essential coverage qualifies as a life event. Be sure to collect and submit the necessary documentation to support your claim.

  1. Contact your current insurance carrier to cancel your individual policy. Provide the desired cancellation date and confirm the termination. Note: Take Command cannot cancel plans on your behalf, and your existing individual health plan will not be canceled automatically. You must contact your carrier directly.

  2. Notify Take Command or HRA Hub of the last coverage date so your account can be updated.

  3. Confirm you are listed as a covered dependent on your spouse's plan.

  4. Submit proof of coverage showing your name on the plan.

  5. Notify HR or your benefits administrator of the new group coverage and provide the effective date. Submit proof of new coverage if requested, such as an insurance card or eligibility letter.

  6. If required, submit a waiver for individual coverage.

⚠️ Important: Some spouse plans require you to be explicitly listed as covered to remain eligible.Additionally, switching to a spouse's group plan makes you ineligible for ICHRA reimbursements, including premiums and non-premium expenses like copays and coinsurance. Remaining ICHRA funds cannot be used for expenses incurred under a spouse's group plan. Reimbursements for eligible expenses incurred before the new group coverage start date can still be submitted, provided they are within the allowed timeframe.


Scenario 3: You no longer have qualifying coverage

If you lose coverage:

  1. Notify your status change in HRA Hub

  2. Stop submitting reimbursement requests

  3. Enroll in a new qualifying plan as soon as possible

Without qualifying coverage:

  • Reimbursements are paused

  • Eligibility is suspended until coverage resumes


Scenario 4: You are switching insurance plans mid-year

If changing plans:

  1. Cancel or end your old plan with the carrier

  2. Enroll in a new individual plan

  3. Upload proof of new coverage

  4. Remove or update recurring premium requests tied to the old plan

Do not overlap recurring reimbursements for multiple plans.Note: Updating your information in the HRA Hub portal does not cancel your policy with the carrier. You must contact your insurance carrier directly to terminate your plan.


Scenario 5: You are on Medicare

Medicare premiums, including Parts A, B, C, D, and Medigap policies, are eligible for reimbursement if you have qualifying Medicare coverage (e.g., Parts A and B together or Part C). To receive reimbursement for Medicare Part B, you must add a new recurring premium entry each plan year and provide supporting documentation, such as a Social Security award letter or premium bill. Similarly, Medicare Part D premiums are reimbursable with proper documentation, such as a Part D plan bill or Social Security statement.

If you have Medicare:

  1. Ensure Medicare Part A and B (or Advantage plan) is active

  2. Upload Medicare documentation in HRA Hub

  3. Submit proof of coverage regularly if required

Medicare qualifies as eligible coverage under ICHRA.


Scenario 6: You choose to waive ICHRA coverage

If you do not want to participate:

  1. Go to your HRA Hub onboarding or settings

  2. Select “Waive Coverage” option

  3. Confirm waiver submission4. During onboarding or re-enrollment, navigate to the "Reimbursement Amount" page and select the option to waive coverage for the year.

  4. Alternatively, your employer can submit a waiver form on your behalf, ensuring it is submitted by the required deadline.

While waived:

  • You cannot receive reimbursements

  • You can re-enroll if eligible coverage is obtained later


Scenario 7: Employment ends

If you transition from full-time to part-time status and your employer only offers ICHRA to full-time employees, your eligibility ends on the date of the transition. This change qualifies as a COBRA event, allowing you to continue ICHRA coverage through COBRA if elected.

If your employment ends:

  1. Your eligibility stops at the end of your employment period

  2. You may still submit eligible expenses incurred before termination

  3. You may have limited post-termination portal access for documentation

After termination:

  • No new reimbursements are allowed

Employees on unpaid leave remain eligible for ICHRA reimbursement as long as their proof of coverage is approved. Monthly reports will continue unless official notice of resignation is received.


Scenario 8: Your proof of coverage is under review or rejected

If your proof is not approved:

  1. Review the rejection reason in HRA Hub

  2. Upload corrected documentation showing:

    • Active coverage

    • Your name

    • Eligible plan type (individual or Medicare)

  3. Resubmit for review

Reimbursements remain paused until approval.

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