Key Deadlines, Processes, and Tools for Managing ICHRA Reimbursement and Enrollment
Managing your ICHRA (Individual Coverage Health Reimbursement Arrangement) plan involves understanding important deadlines, processes, and tools to ensure smooth implementation and compliance. Below is a comprehensive guide to help you navigate these aspects effectively.
Key Deadlines for ICHRA Plan Management
Finalizing Reimbursement Amounts
September: Finalize plan design updates, including reimbursement amounts, by mid-September to meet the 90-day advance notice requirement for employees. This ensures a smooth start for plans beginning January 1.
Early December: If adjustments are needed after reviewing open enrollment plan rates (available mid-November), finalize changes by early December to ensure they take effect on January 1. Changes made later may delay implementation.
Open Enrollment and Rate Visibility
Mid-November: New insurance rates for the upcoming plan year are typically visible in the Take Command shopping tool by early to mid-November, allowing employees to compare and select plans.
Ending an ICHRA
You can terminate your ICHRA at any time if switching to a small group health plan. The 90-day notice requirement applies only to continuing or renewing an ICHRA, not to ending it.
Rules for Making Changes
Annual Changes
Changes to ICHRA reimbursement amounts must be made during the renewal window (September to early December) and will apply to all eligible employees starting with the new plan year.
Mid-Year Changes
Mid-year changes to reimbursement amounts are generally not allowed, as employees select coverage based on the original allowance during open enrollment. Plan changes should take effect at the start of a new plan year.
Transition to New Tools
For the 2026 plan year, all ICHRA activities and documents are managed in HRA Hub, replacing the Legacy platform. Once your plan design is approved in HRA Hub, employee notices and related documents will be generated there. If you only see 2025 materials, switch to HRA Hub for 2026 documentation.
Example Reimbursement Amounts for 2026
The following are the base allowance amounts for 2026:
Single: $800.00
Couple: $1,200.00
Kids: $1,500.00
Family: $1,500.00
These amounts replace the prior year’s allowances and serve as a guideline for planning contributions.
FAQs
Do I need to take action to keep the same ICHRA configuration?
No action is required if you wish to maintain the same configuration and reimbursement amounts. Your existing setup will automatically carry over unless changes are requested.
When do changes to reimbursement amounts take effect?
Changes made during the renewal window will take effect at the start of the new plan year (e.g., January 1, 2026). By adhering to these guidelines and timelines, you can ensure a seamless ICHRA plan management experience for your organization and employees.