What does a Qualified Plan for ICHRA look like?

The Individual Coverage HRA requires employees and their dependents to be enrolled in individual health insurance for each month the employee and their family members are reimbursed through ICHRA. In order to be qualified individual coverage, it must meet the minimum requirements as outlined in Public Health Services (PHS) Act Section 2711 and Section 2713

These two provisions require that the employee's plan has:

  • No annual or lifetime limits on the dollar amount for coverage of essential health benefits  

  • Full coverage of preventative health services to be covered with no shared cost to the insured

In other words, the plan needs to meet Minimum Essential Coverage through an individual marketplace plan. 

Which Plans Qualify?

Different from other types of HRAs, with ICHRA, the ONLY  types of health insurance that qualify are:

  1. Major Medical insurance offered on or off the Exchange (bronze, silver, or gold plans) 

  2. Medicare (Part A and B together, or Part C)

  3. Catastrophic Coverage for qualified individuals

  4. Student health insurance

The following chart explains which plans are allowed with ICHRA

Which plans are not qualified?

Plans that do not qualify as individual coverage include your spouse's employer group plan, Medicaid, TRICARE, COBRA, short-term plans, indemnity plans, sharing plans, and preventative-only MEC plans.

For more information, read about ICHRA compliant individual insurance plans

Still not sure where to start? Check out our Admin Resource Center for more resources and support.

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