At this time, no. COBRA coverage is considered a continuation of a group health plan and therefore does not meet the criteria for individual coverage under ICHRA.
The guidelines for ICHRA state that employees with COBRA will need to purchase a separate individual insurance plan to participate in ICHRA. You can learn more about what plans are compliant with ICHRA in this help article. To qualify for ICHRA participation and reimbursements, employees must enroll in a new individual health insurance plan that complies with the Public Health Service Act (PHS Act) Sections 2711 and 2713.
