Yes. Employees enrolled in Medicare can participate in an Individual Coverage HRA (ICHRA) as long as they are enrolled in Medicare Part A and Part B, or Medicare Part C (Medicare Advantage).
Does Medicare qualify as individual health insurance for ICHRA?
Yes. Medicare is considered qualifying individual health coverage for ICHRA participation.
You may participate in your employer's ICHRA if you are enrolled in:
Medicare Part A and Part B
Medicare Part C (Medicare Advantage)
If you are not enrolled in the required Medicare coverage, you are not eligible to participate in the ICHRA.
Which Medicare premiums can be reimbursed through an ICHRA?
Depending on your employer's plan design, an ICHRA may reimburse eligible Medicare premiums, including:
Medicare Part A premiums (if applicable)
Medicare Part B premiums
Medicare Part C (Medicare Advantage) premiums
Medicare Part D prescription drug premiums
Medicare Supplement (Medigap) premiums
Your employer determines which expenses are eligible for reimbursement under the ICHRA.
Can I have Medicare and an ICHRA at the same time?
Yes. Medicare and an ICHRA can work together.
Employees enrolled in qualifying Medicare coverage may use their ICHRA to receive tax-free reimbursements for eligible premiums and medical expenses, subject to their employer's plan rules.
Can I receive premium tax credits if I have Medicare and an ICHRA?
No. Individuals enrolled in Medicare are not eligible for Marketplace premium tax credits.
If you have Medicare coverage, you cannot receive Affordable Care Act (ACA) premium tax credits regardless of whether you are offered an ICHRA.
What happens if I enroll in Medicare after joining an ICHRA?
If you enroll in Medicare after already participating in an ICHRA:
Notify Take Command and your employer as soon as possible.
Update your coverage information if requested.
Continue maintaining qualifying Medicare coverage.
Submit eligible reimbursement requests according to your employer's plan rules.
Maintaining qualifying coverage is required to continue participating in the ICHRA.
What Medicare coverage is required for ICHRA participation?
To participate in an ICHRA while on Medicare, you must be enrolled in one of the following:
Coverage Type | Eligible for ICHRA Participation |
Medicare Part A + Part B | Yes |
Medicare Part C (Medicare Advantage) | Yes |
Medicare Part A only | No |
Medicare Part B only | No |
Key takeaway
Employees enrolled in Medicare may participate in an ICHRA if they are enrolled in Medicare Part A and Part B or Medicare Part C (Medicare Advantage). Eligible Medicare premiums may be reimbursed through the ICHRA based on the employer's plan design.