An Employer’s Guide to Meeting ICHRA Notice Requirements

Employers gain cost benefits, flexibility advantages, and employee-facing perks worth leveraging when they implement an Individual Coverage Health Reimbursement Arrangement (ICHRA) model; however, they must be keenly aware of requirements for setting up an ICHRA, guidelines to follow, and administrative timelines for enrollment and reporting. Because ICHRAs are new to many employers, this is the guide employers need to help navigate ICHRA notice requirements.

Communicating a Newly Implemented ICHRA

Instead of the one-size-fits-all nature of the costly group health insurance plan, ICHRA allows participating employees to choose their own specific individual health insurance coverage and submit reimbursement requests for out-of-pocket costs. It’s a significant improvement to the outdated nature of traditional group plans.

There can be a learning curve with how employers roll out and communicate with teams about how an ICHRA works. They’ll need to understand what responsibilities now fall on them regarding individual enrollment timelines. They’ll have questions about what is considered reimbursable and the company’s processes for submitting and paying out those requests. Consider carving out an employee-facing library of resources with terms, definitions, benefits, and timelines.

It’s also imperative that employers direct employees to one person or team responsible for managing the ICHRA. For some small companies, this might be a dedicated person in Human Resources. For others, outsourcing to a third-party administrator partner, like W3LL, can be the most efficient way to develop a system for tracking, managing, and operating an ICHRA reimbursement model.

ICHRA Notice Requirements Defined

The big piece of the ICHRA communication puzzle, and probably the most important, is the ICHRA notice requirement. Because participating employees are only eligible for reimbursement if they have proof of purchasing an outside insurance plan, employers need to ensure employees understand this requirement. The ICHRA only applies to those who have health coverage through the ACA Marketplace or private sectors.

The employee notice requirement refers to the official notice employers present to their teams. This will serve as a guide for them for their unique, individual next steps to browse and purchase an insurance plan from the Marketplace. If employees are used to the traditional group health plans, they’ll be new to shopping for their own coverages and likely unfamiliar with how the Marketplace works.

The timeline to prove coverage is the most critical aspect of the ICHRA notice requirement. ICHRAs must provide a 90-day notice to all eligible staff regarding the:

• ICHRA Rollout Plan
• ICHRAs Interactions with Premium Tax Credits
• Qualifying 60-Day Special Enrollment Period

This applies to existing employees who might be eligible now as well as any new employees onboarded throughout the year. Employers can extend these benefits to any employee type, including full-time, part-time, seasonal, or temporary placement.

What Employers Need to Include in the ICHRA Notice

Here is the full roster of details to communicate with a ICHRA notice to ensure compliance with ICHRA communication.

Avoid potential coverage lapses when transitioning to the Marketplace by providing guidelines needed to successfully navigate their own coverage enrollment and take advantage of the ICHRA reimbursement options.

Make sure ICHRA notice includes:

• The reimbursement dollar amounts an ICHRA plans to offer
• Clear dates for when the ICHRA reimbursement model begins
• Well-detailed contact information for dedicated ICHRA contact personnel
• A library of resources with FAQs, definitions, and marketplace tutorials
• A statement of Special Enrollment Period eligibility
• A statement that the company ICHRA is not a QSEHRA

Don’t overburden staff with figuring out the nuances of every detail. W3LL can help by overseeing companywide communication through standard notice templates and dashboard management of reimbursements and participation. Contact our expert team to help you prepare your ICHRA notice and see what else we can help you streamline with your ICHRA this year!