Employees enrolled in an ICHRA through Take Command Health can be reimbursed only for premiums from ACA-compliant individual health insurance plans, Medicare coverage, catastrophic plans (if eligible), and student health insurance.
What health insurance plans qualify for an ICHRA?
ICHRA only allows reimbursement for qualified individual health insurance coverage that meets federal ACA and IRS requirements.
Eligible plan types include:
Major medical individual health insurance plans
Purchased on Healthcare.gov (Marketplace)
Purchased off the Marketplace (private individual market plans)
Bronze, Silver, Gold, or Platinum ACA-compliant plans
Medicare coverage
Medicare Part A and B together, or Medicare Part C (Advantage)
Catastrophic health plans
Available only if you are under 30 or qualify for a hardship exemption
Student health insurance plans
School-sponsored individual coverage that meets eligibility requirements
Note: On Medicare, specifically you must have parts A+B or C (Medicare Advantage) to qualify, but as long as you have either of those, all Medicare supplements are reimbursable.
The following chart explains which plans are allowed with ICHRA
What health insurance plans do NOT qualify for ICHRA?
The following plans are explicitly not eligible for reimbursement under ICHRA:
Employer-sponsored group health plans (including spouse’s plan)
Medicaid
TRICARE
Short-term health insurance plans
Health care sharing ministry plans
Indemnity-only plans
Preventive-only MEC plans without full coverage
Why are those the only plans that qualify?
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. Additionally, expenses must be incurred while an individual’s insurance plan is active. ICHRA does not allow reimbursement for premiums or expenses incurred prior to the insurance coverage start date or before the ICHRA plan activation.
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
Plan compliance verification, ensuring the health plan aligns with ICHRA eligibility, including proof of ACA compliance or individual plan requirements.
In other words, the plan needs to meet Minimum Essential Coverage through an individual marketplace plan.
Reimbursement Rules and Processes
ICHRA monthly allowances can be used for reimbursing individual premiums and qualified medical expenses for employees and dependents, subject to the reimbursement structure set by the employer.
Reimbursements are conditional upon proof of enrollment in eligible health plans, with allowable expenditures regulated by ICHRA policy and timing.
How do I find compliant plan?
Take Command Health is here to help! We can help you navigate your options. Reach out to our support team via chat or at support@takecommandhealth.com, let us know what state you're in, and we can help point you in the right direction! To claim reimbursements, employees must provide proof of active enrollment in an ICHRA-compliant plan via their employer’s portal, including evidence of premium amounts and compliance with ACA or other eligibility rules.
It's very important to remember that you cannot accept a premium tax credit if you are claiming reimbursement through ICHRA. Here is a little more about how ICHRA affects your tax credit.
For more information, read on our blog about ICHRA-compliant individual insurance plans.