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.
Reimbursements paused unexpectedly? If your reimbursements were active and then stopped without explanation, the most common causes are: (1) your proof of coverage expired and a new document is needed, (2) your qualifying coverage lapsed or changed to a non-qualifying plan, or (3) your employer changed your eligibility class. Check your portal for any compliance action items before contacting Customer Experience.
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
When can I enroll — and what if I miss the enrollment window?
ICHRA enrollment is tied to your employer’s plan year and the federal rules for individual health insurance. You can enroll (or change plans) during these windows:
When you first become eligible — new employees typically have 30–60 days from their start date or eligibility date to select coverage and submit proof. Check your offer letter or ask your HR administrator for your specific window.
During your employer’s annual Open Enrollment period — usually 30–60 days before the plan year starts.
After a Qualifying Life Event (QLE) — this opens a Special Enrollment Period (SEP), typically 60 days from the event date. Common QLEs that qualify:
Marriage, divorce, or legal separation
Birth or adoption of a child
Loss of other qualifying coverage (e.g., leaving a spouse’s plan, job change, end of COBRA)
Moving to a new coverage area
Gaining or losing a dependent’s eligibility (aging off a plan, divorce)
Missed your enrollment window? If you did not enroll during your initial window or Open Enrollment, you generally cannot enroll mid-year unless you have a QLE. Contact your HR administrator — they can confirm whether any window is still open for your account, or whether you need to wait for the next Open Enrollment period. Take Command Customer Experience cannot override enrollment windows; only your employer can request an exception.
If you experienced a QLE and need to change your coverage or enroll mid-year, submit your QLE documentation through HRA Hub as soon as possible — the 60-day window starts from the date of the event, not the date you became aware of the option.
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