To be eligible for an ICHRA, an employee must be offered coverage by their employer, enroll in an eligible individual health insurance plan (or Medicare), and submit valid proof of that coverage through HRA Hub.
What determines ICHRA eligibility
Eligibility requires BOTH employer and employee conditions to be met
An employee can only participate in ICHRA if:
The employer has designated the employee as eligible
The employee is enrolled in qualifying health coverage
The employee submits proof of that coverage
All three requirements must be satisfied at the same time.
Step 1: Employer must offer ICHRA eligibility
You must be included in an eligible employee class
Employers define which employees can participate based on allowed job-based categories such as:
Full-time employees
Part-time employees
Seasonal employees
Salaried or hourly employees
Geographic location groups
Employees under specific collective bargaining agreements
If you are not included in an eligible class:
❌ You cannot participate in ICHRA
❌ You are not eligible for reimbursements
Step 2: You must enroll in qualifying health coverage
Only specific types of coverage make you eligible
To participate in ICHRA, you must have ONE of the following:
ACA-compliant individual health insurance (on or off exchange)
Medicare Part A and B or Medicare Advantage
Optional qualifying coverage (in limited cases):
Catastrophic plans (if eligible)
Student health insurance plans
Plans that DO NOT qualify
You are not eligible if you only have:
Spouse’s employer-sponsored group plan
Medicaid (in most cases)
TRICARE
COBRA
Short-term health insurance
Health sharing ministry plans
Indemnity or discount-only plans
If you only have these:
❌ You cannot receive ICHRA reimbursements
Step 3: You must provide proof of coverage
Proof is required before reimbursements begin
You must upload documentation that clearly shows:
Your name
Insurance carrier and plan name
Active coverage status
Coverage start date
Proof that the plan is currently active
Without approved proof:
❌ Reimbursements are paused
❌ You are not considered fully compliant
Step 4: Maintain ongoing eligibility
Eligibility is not one-time—it must be maintained
You must continue to:
Keep qualifying coverage active every month
Update proof of coverage when changes occur
Ensure your plan remains eligible under ICHRA rules
If coverage lapses:
Reimbursements stop until coverage is restored