This article is for employers administering an Individual Coverage HRA (ICHRA) or Qualified Small Employer HRA (QSEHRA) through Take Command who want to understand employee waivers, billing, and recordkeeping requirements.
Can employers waive an employee's HRA benefit?
Generally, no. Employees are responsible for electing to waive their own HRA benefit through the Member Portal.
If an employee cannot access their account, they should contact Take Command Customer Experience for assistance.
How do employee waivers affect billing?
Billing is based on employee participation status. Employees who remain eligible and have not completed a waiver may continue to appear on your invoice.
To help ensure billing is updated for the next cycle, employees should submit their waiver by the 24th of the month.
Which employee statuses are excluded from billing?
Employees generally are not billed when their status is:
Waived
Terminated
Employees in other active participation statuses may continue to appear on employer invoices.
What records should employers keep?
Employers should retain documentation showing that an employee voluntarily elected to waive the HRA.
If required by the enrollment process, employers should also complete any applicable attestations confirming required employee notices were provided.
Retain waiver documentation according to your organization's record retention policies.
What if an employee says they waived coverage but still appears on the invoice?
Review the employee's participation status in the Employer Portal.
If the employee:
Submitted the waiver after the monthly billing deadline, the update may appear on a future invoice.
Does not show a Waived status after completing the waiver, contact Take Command Customer Experience for assistance.
Can employees waive their HRA for future plan years?
Yes. Waivers apply only to the current plan year.
Employees who remain eligible during a future plan year must complete enrollment again and decide whether to participate or waive their benefit for that new plan year.
When does this article not apply?
This article does not apply if:
An employee has already been terminated from the employer's roster.
The employee is no longer eligible to participate in the HRA.
Termination and waiver are different participation statuses and may have different administrative and billing implications.
Key takeaway
Employees are responsible for completing their own HRA waiver through the Member Portal. Employers should monitor employee participation statuses, retain waiver documentation, and ensure waivers are completed before the monthly billing deadline to help maintain accurate billing.