Your ICHRA runs on a calendar year, which means that each Fall is the time to think about your needs for the following year and renew your program. Each calendar year offers you an opportunity to reset and update your program design for your employees - or keep it exactly the same!
When do I need to make any design updates and renew my HRA?
All existing HRA administrators should make design changes/updates and renew their HRA program for 2024 by September 22nd, 2023 choosing to either keep the same existing design or make changes for next year’s program. If we don’t hear from an admin, the HRA will auto-renew with no changes on September 22nd.
We know, that sounds early.
But here's the deal: ICHRA guidance says that you have to provide your employees with a 90-day notice before each new program year. That means that 90 days before January 1st 2024, they should be notified of their benefits for next year. We will generate your 2024 Employee Notice for you and provide it to your employees via their Take Command employee portals.
90 days from January 1st is October 3rd, and we will need a few days to generate documents for your employees in time, so September 22nd is the ideal final day for you to make changes and renew. Don't worry, if you need to make some changes in October, we can still help you.
So, why does the guidance require a 90-day notice?
Open Enrollment begins November 1st, so giving your employees a little bit of notice helps them prepare to shop for their individual plans for next year.
Wait, I just started my HRA mid-year. How does that work with the upcoming renewal?
HRA program years run on a calendar year to follow the individual health insurance market. So even if you started your HRA in August, it will renew on January 1 (at the same time individual plans will renew). You'll still want to let us know how you want to design your program for 2024 and let your employees know about Open Enrollment coming up (don't worry - we'll send lots of reminders!). On a positive note, this allows employees a chance to make changes to their health plan, if needed, for 2024!
What do I need to think about when planning for my 2024 ICHRA?
If your program is working for you this year, then you can keep it all exactly the same! But, if you've had some big changes to your staff, your budget, or your needs for the upcoming year, you may want to switch it up!
Here are some things to think about:
Do you want to change your ICHRA allowances?
Do you need to make adjustments to your Employee Class Design? Or do you need to add or remove a class?
Do you want to start or stop reimbursement for medical expenses, in addition to monthly premiums?
Do you want to add or remove an eligibility wait period for new hires, which determines how long they must be employed before receiving the benefit?
I'm an ALE. Do I need to re-run Affordability?
If you are an ALE (this means you have more than 50 full-time employees), and you want everything to stay the same, we would still recommend letting us run a new affordability analysis for 2024 since the affordability threshold percentage is changing slightly, your employees are now one year older, and their wages may have changed. While we don’t expect big changes, all of these factors can affect your required reimbursement rate. Don’t worry--we will run your numbers on our end to make sure you stay compliant and will follow up with our recommendations.
So, how do I tell you what I want?
Starting August 15th you'll be able to complete your renewal and check a few boxes through your Administrator Member Portal to make your 2024 selections.
Help! I need to talk some things out.
That's what we're here for! Use the chat function in the bottom right corner of your screen to talk with our Client Success team or schedule a call with us, and we'd be happy to help you think through what's best for you and your team.
Still not sure where to start? Check out our Admin Resource Center for more resources and support.