Yes. Being newly offered an ICHRA or QSEHRA is considered a qualifying life event that allows employees to enroll in or change individual health insurance outside of Open Enrollment through a Special Enrollment Period (SEP), typically for 60 days from the date they become eligible.
Does an HRA create a qualifying life event?
Yes. When an employer offers you:
An ICHRA (Individual Coverage HRA), or
A QSEHRA (Qualified Small Employer HRA)
You are considered newly eligible for employer-sponsored health reimbursement coverage, which triggers a Special Enrollment Period for individual health insurance.
This allows you to enroll in or change a qualifying individual health plan outside of the standard Open Enrollment period.
How long do I have to enroll in a plan?
Once you become newly eligible for an HRA:
You typically have 60 days from your HRA eligibility date to enroll in or change a health insurance plan
Coverage timing depends on when you select a plan within that window
If you miss this window, you generally must wait until the next Open Enrollment period
When does the Special Enrollment Period apply?
A Special Enrollment Period is triggered when:
You are newly offered an ICHRA or QSEHRA
Your employer sets a new HRA start date mid-year
You first become eligible for HRA benefits after hiring or a status change
This SEP allows you to enroll even if it is outside the annual Open Enrollment period.
Do I still need a qualifying health plan?
Yes. To participate in an HRA, employees must be enrolled in qualifying coverage such as:
Individual Marketplace (ACA) plans
Private individual health insurance plans
Medicare (where applicable)
Short-term plans and non-ACA compliant coverage typically do not qualify.
What happens if my HRA starts on January 1?
If your HRA starts on January 1:
You generally enroll during the standard Open Enrollment period (Nov 1–Dec 15 in most states)
Coverage begins at the start of the new plan year
No additional Special Enrollment Period is needed
What if my HRA starts outside Open Enrollment?
If your HRA starts mid-year:
You receive notice of your HRA eligibility and start date
You qualify for a Special Enrollment Period
You must enroll in a qualifying plan within the SEP window (typically 60 days)
Your coverage must be active by your HRA start date to receive reimbursements
Can I use the SEP for any insurance plan?
No. The Special Enrollment Period created by HRA eligibility applies to:
Individual Marketplace plans
Private individual health plans that meet ACA requirements
It does not apply to employer group plans or COBRA enrollment rules.
What happens if I miss the enrollment window?
If you do not enroll during your SEP:
You generally cannot enroll in or change plans until the next Open Enrollment period
You may lose eligibility for HRA reimbursements during the gap period
You may need to wait for another qualifying life event or Open Enrollment
Does offering an HRA let me cancel my current insurance?
Not automatically. You may choose to:
Keep your current plan
Switch plans using your SEP
Enroll in a new plan that better fits your HRA reimbursement
However, cancelling coverage does not extend or reopen your SEP window.n; events such as marriage, divorce, having a baby, and moving qualify.
For more information, read our blog post titled Special Enrollment Periods and ICHRA make signups easier for everyone.