Yes. To participate in an ICHRA, employees will need to maintain coverage in a qualified individual health plan. Open Enrollment for individual plans varies by state, but in general runs from November 1st to December 15th each year. Outside of Open Enrollment, individuals need a qualifying life event to trigger a Special Enrollment Period to purchase a plan; events such as marriage, divorce, having a baby, and moving qualify.
But good news! Employers offering an ICHRA or QSEHRA will trigger a special enrollment period for employees, giving them 60 days from their eligibility date to buy a plan. Which means employers can set up an ICHRA at any time during the year and employees are able to shop for qualified individual plans on the marketplace year-round.
Employees with a Jan 1 ICHRA start date will need to purchase insurance during the regular open enrollment season (Nov 1- Dec 15 in most states).
For more information, read our blog post titled Special Enrollment Periods and ICHRA make signups easier for everyone.