No. If you are enrolled in a spouse’s employer-sponsored group health plan, you are not eligible to participate in an ICHRA unless you first opt out of that group plan and enroll in qualifying individual health insurance.
Can I participate in an ICHRA if I’m on my spouse’s employer plan?
No. Employees enrolled in a spouse’s employer-sponsored group health plan cannot participate in an ICHRA while that coverage is active.
This is because ICHRA rules require employees to be enrolled in individual health insurance coverage, not group coverage.
Why does a spouse’s group plan make me ineligible?
ICHRA participation requires enrollment in individual market coverage.
A spouse’s employer plan is considered group health insurance, even if:
You are enrolled as a dependent
You pay part of the premium
The coverage meets or exceeds ACA standards
Because it is group coverage, it does not meet ICHRA eligibility requirements.
What do I need to do to become eligible for ICHRA?
To participate in your employer’s ICHRA, you must:
Opt out of your spouse’s employer-sponsored group health plan
Enroll in a qualifying individual health insurance plan
Provide proof of coverage in your Take Command account
Once you are enrolled in individual coverage, you can begin receiving reimbursements.
What types of plans qualify for ICHRA?
To be eligible, you must have individual coverage, such as:
ACA Marketplace plans (Bronze, Silver, Gold, Platinum)
Off-exchange individual major medical plans
Medicare Parts A and B or Medicare Advantage (Part C)
Certain student health insurance plans
Catastrophic plans (if eligible based on age or exemption status)
Group health plans, including a spouse’s employer plan, do not qualify.
Can I use my spouse’s group plan and ICHRA at the same time?
No. You cannot be reimbursed through an ICHRA while enrolled in a spouse’s employer group plan.
You must choose one coverage path:
Stay on spouse’s group plan (no ICHRA participation), or
Opt out and enroll in individual coverage to use the ICHRA
What happens if I switch from my spouse’s plan to individual coverage?
If you switch:
You must enroll in an individual health insurance plan
You must submit proof of coverage in your Take Command portal
Your ICHRA reimbursements will begin once coverage is verified
There is typically no retroactive reimbursement for time spent on group coverage.
Can my spouse and I have different coverage types?
Yes. Household members can choose different coverage paths:
Your spouse may remain on their employer group plan
You may enroll in individual coverage and use ICHRA
However, you cannot personally be covered under both a group plan and ICHRA at the same time.
What if I’m unsure whether my plan qualifies?
If you are unsure:
Check whether your plan is individual or employer group coverage
Review your eligibility in your Take Command portal
Submit documentation for verification
Only individual coverage plans qualify for ICHRA reimbursement.