No. Employees who are enrolled in a spouse’s employer-sponsored group health plan are not eligible for ICHRA reimbursements unless they disenroll from that group plan and enroll in an individual health insurance plan.
Can ICHRA reimburse employees on a spouse’s group health plan?
No. Employees cannot receive ICHRA reimbursements if they are enrolled in a spouse’s employer-sponsored group health plan.
To be eligible for ICHRA, employees must be enrolled in individual health insurance coverage, not group coverage.
Why are spouse group plans not eligible?
Spouse employer plans are not eligible because they are classified as group health coverage, not individual coverage.
ICHRA rules require employees to have one of the following:
An individual ACA-compliant health insurance plan
Medicare (Parts A and B or Medicare Advantage)
Other qualifying individual coverage types
Group coverage through a spouse does not meet these requirements, even if the employee is only covered as a dependent.
What must employees do to become eligible?
To participate in an ICHRA, employees must:
Opt out of their spouse’s employer-sponsored group health plan
Enroll in an individual health insurance plan (Marketplace or off-exchange ACA plan)
Submit proof of coverage in HRA Hub
Maintain active coverage for each month they receive reimbursement
Eligibility begins only after qualifying coverage is active.