ICHRA Enrollment Support

Employees who have never bought an individual plan need someone to help them buy one.

An ICHRA moves plan selection to the employee. The allowance only works when employees can find a plan, enroll on time and submit reimbursements without confusion.

Ask Whether an ICHRA Fits

What To Know

What good enrollment support covers.

Before Enrollment

Explain the allowance, the classes and the dates in plain language before the notice goes out.

Choosing a Plan

Employees compare networks, drugs and costs. A named person or team should be available to answer questions.

Enrolling on Time

Enrollment windows are tight. Track who has enrolled and follow up before the deadline.

Proof of Coverage

Employees confirm they have individual coverage so the allowance can be paid. Decide how that proof is collected.

Reimbursement Questions

Employees ask what is reimbursable and when. Publish one clear process.

Ongoing Help

Questions continue after enrollment, through claims, life events and renewal. Plan for the whole year.

The Numbers

What Employees Must Do, and When

Enrollment is the employee’s job, and the employer has to run the process around it: the notice, the proof of coverage and the right to opt out.

The sequence

Step What the rule says Timing
Notice Written notice with the allowance, plan year dates, the opt-out right, the premium tax credit consequence and the special enrollment information At least 90 calendar days before the plan year begins
Plan selection A person newly offered an ICHRA has a special enrollment period to choose a marketplace plan 60 days before the date coverage can first take effect; if the 90-day notice was not required, 60 days before or after
First proof of coverage A third-party document such as an insurance card, or an attestation stating the enrollment, the start date and the carrier name Before the first reimbursement
Each later reimbursement Proof that the participant stayed enrolled for the month the expense was incurred Each time
Opt-out A participant must be permitted to opt out and waive future reimbursements Once per plan year, offered before the plan year begins

Sources: 26 CFR 54.9802-4(c)(4), (c)(5) and (c)(6); 45 CFR 155.420(c)(3) and (d)(14).

An illustrative timeline for January 1, 2028

The notice must be delivered by October 3, 2027. The special enrollment window opens 60 days before January 1, on November 2, 2027. A plan selected before January 1 starts on January 1. The employer collects proof of the plan from each participant and begins reimbursing from the first month of coverage.

Illustrative. Federal rules govern the special enrollment period, and marketplace deadlines for general open enrollment can differ.

What the employer cannot do

An employer may not offer a participant a choice between an ICHRA and a traditional group health plan. The two are offered to different classes. The employer may rely on the employee’s documents or attestation unless it actually knows the coverage is missing.

Source: 26 CFR 54.9802-4(c)(2) and (c)(5)(iii).

Questions We Get

The questions employers ask about ICHRA enrollment help.

Who helps employees today?

Our team supports employees, and our chat assistant answers common questions at any hour.

Do employees pick any plan?

Employees choose an individual market plan. The employer cannot require a particular carrier.

When must employees enroll?

During the enrollment window that applies to them, such as open enrollment or a special enrollment period. Our notice deadlines page covers the timing.

What proof is needed?

Employees confirm their individual coverage so reimbursement can be paid. The plan sets the exact process.

How do employees get reimbursed?

The employer sets the process, such as submitting proof of premium. Keep it simple and publish the dates.

What if an employee misses enrollment?

They may have to wait for the next enrollment opportunity, which is why follow-up matters.

How much work is this for HR?

Less than it looks when someone owns it. We can handle most employee questions so HR does not have to.

General information about individual coverage HRAs, not legal or tax advice. Plan-specific questions belong with ERISA counsel and your tax advisor, and we will bring them in.

Sources

Where these details come from.

This page summarizes public guidance reviewed in October 2026. Rules change, so confirm current requirements with counsel.

CMS: Individual Coverage HRAs →

U.S. Department of Labor: Employee Benefits Security Administration →

Let’s Get to Work

Send us your renewal.

We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.

What to send

The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier

Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.

CFH Insurance Consultants

An independent employee benefits consulting firm. We look at the entire benefits program: cost, plan performance, risk and administration.

Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →

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