To use an ICHRA, you must enroll in an ACA-compliant individual health insurance plan such as a plan purchased through the Marketplace or directly from an insurance carrier, and then submit proof of coverage in HRA Hub to receive reimbursements.
What counts as an ICHRA-compliant plan?
An ICHRA-compliant plan is an individual health insurance plan that meets Minimum Essential Coverage (MEC) requirements under the Affordable Care Act.
Eligible plans include:
Individual or family plans purchased through the federal or state Marketplace
Individual plans purchased directly from an insurance carrier (off-exchange)
Medicare (Parts A and B or Medicare Advantage plans)
These plans must provide ACA-compliant coverage, including preventive services and essential health benefits.
What plans do NOT qualify for ICHRA?
The following types of coverage are not eligible for ICHRA reimbursement:
Spouse’s employer-sponsored group health plan
Medicaid
TRICARE
COBRA coverage
Short-term health plans
Fixed indemnity plans
Healthcare sharing ministry plans
Preventive-only or limited benefit plans
If you are enrolled in one of these, you are not eligible to receive ICHRA reimbursements.
When can I shop for a plan?
You can shop for an individual health insurance plan during:
Open Enrollment (typically once per year)
A Special Enrollment Period (SEP) triggered by a qualifying life event
Becoming newly eligible for an ICHRA
If you become newly eligible for an ICHRA mid-year, you generally have 60 days from your eligibility start date to enroll in a qualifying plan.
How do I shop for a plan step-by-step?
Go to the federal Marketplace (Healthcare.gov) or your state exchange
Enter your ZIP code and household information
Compare available ACA-compliant plans
Filter by:
Premium cost
Deductible
Provider network
Prescription coverage
Select a plan that meets your needs
Complete enrollment directly through the Marketplace or carrier
Save your confirmation and ID card
You will need this documentation to submit proof of coverage in HRA Hub.
How do I get reimbursed after I enroll?
To receive ICHRA reimbursement:
Enroll in an eligible individual health insurance plan
Pay your monthly premium to the insurance carrier
Log in to HRA Hub
Upload proof of coverage (insurance ID card or confirmation letter)
Submit premium reimbursement requests as required
Reimbursements are only processed after valid proof of coverage is approved.
Can I use premium tax credits with ICHRA?
No. If you accept an ICHRA:
You cannot also receive Advance Premium Tax Credits (APTC)
You must choose either the ICHRA benefit or Marketplace subsidies
You will typically need to notify the Marketplace that you are participating in an ICHRA.
What if I already have a health plan?
You can still use your existing plan if it is ACA-compliant.
You must:
Confirm the plan meets ICHRA eligibility rules
Upload proof of coverage in HRA Hub
Ensure the plan is not an excluded coverage type
If your plan is not compliant, you will not be eligible for reimbursement.
Do I have to use a specific insurance carrier?
No. You can choose any eligible ACA-compliant plan available in your area.
Your options depend on:
Your ZIP code
Available carriers in your market
Plan availability during enrollment periods
What happens if I enroll in a non-qualifying plan?
If your plan does not meet ICHRA requirements:
Your claim will be denied
You will not receive reimbursement
You may need to enroll in a qualifying plan to become eligible
Only ACA-compliant individual plans and Medicare qualify.
What does NOT affect plan eligibility?
The following do NOT make a plan ineligible on their own:
Higher premiums
Plan metal level (Bronze, Silver, Gold, Platinum)
Whether the plan is on-exchange or off-exchange
Eligibility is based on whether the plan is ACA-compliant, not cost or network size.
