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ICHRA Employee: Waiving Your HRA When You Have Medicaid or Other Non-Qualifying Coverage

This article is for employees participating in an Individual Coverage Health Reimbursement Arrangement (ICHRA) administered through Take Command who have health coverage that isn't eligible for ICHRA reimbursement.

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Written by David Hung

If you're enrolled in Medicaid or another type of health coverage that doesn't qualify for ICHRA participation, you may choose to waive your employer's ICHRA benefit.

Can I participate in an ICHRA if I have Medicaid?

Generally, no. Medicaid isn't considered individual health insurance for ICHRA purposes and doesn't qualify for reimbursement through an ICHRA.

If you're enrolled in Medicaid, you may choose to waive your employer's ICHRA.


What if I have other non-qualifying coverage?

If your current health insurance doesn't meet your employer's ICHRA requirements, you may choose to:

  • Obtain qualifying individual health insurance, or

  • Waive your ICHRA benefit.

Your eligibility depends on the type of health insurance you have.


How do I waive my ICHRA?

  1. Sign in to your Take Command Member Portal.

  2. Begin onboarding or annual renewal.

  3. Select the option to waive your ICHRA.

  4. Confirm your decision.


When does this article not apply?

This article explains waiver decisions related to Medicaid and other non-qualifying coverage.

It does not explain how to enroll in qualifying individual health insurance.


Key takeaway

Employees enrolled in Medicaid or another non-qualifying health plan may choose to waive their ICHRA. If you later obtain qualifying individual health insurance, you may be able to participate in your employer's HRA if you're otherwise eligible.

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