Which plans Qualify for ICHRA?

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

  1. Major Medical health insurance offered on or off the exchange. These are major medical, ACA-compliant plans and are often referred to as metal tiers because their names include bronze, silver, or gold.
  2. Medicare Part A and B or Part C 
  3. Catastrophic plans which are limited to those under age 30 or who qualify for a hardship exemption
  4. Student health insurance 

Note that on Medicare, specifically you must have parts A+B or C to qualify, but as long as you have one of those, all Medicare supplements are reimbursable.

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.

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

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 need to meet Minimum Essential Coverage through an individual marketplace plan. 

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!

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. 

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