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.
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.
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).
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.
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 →
More ICHRA questions and the industries they affect.
Plan Options Near Worksites
Which individual plans exist at each site.
Retiree Coverage
Retirees and Medicare.
Hours and Mid-Year Changes
Measuring hours and status changes.
ICHRA for Home Health and Social Services
Field staff and variable schedules.
ICHRA for Restaurants and Hospitality
Tipped, hourly and seasonal staff.
ICHRA for Child Care and Early Education
Teachers, aides and school-year schedules.
ICHRA Pros and Cons
What employers gain and what they take on.
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.
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.
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. →
Cookies on This Site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential: needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics: tell us which pages get read, so we know what is worth writing more of.
- Advertising: set by third parties such as ad and social platforms to measure and target campaigns.

