ICHRA

What you should know about ICHRA plan documents

by Keely S.

The ICHRA, or individual coverage HRA, gives employers the ability to design and customize a plan  for their organization. There are many rules surrounding ICHRA and other HRAs, which can change from year to year. If keeping up with changing regulations sounds overwhelming, take heart! The ICHRA platform from Take Command Health has built-in, automatic updates to ensure compliance. It will also ensure you have all the ICHRA plan documents you and your employees need. Let’s look at those.

ICHRA plan documents

Legal Agreement

The legal agreement establishes the ICHRA for the employer. It should include:

  1. Named fiduciaries and plan administrators and their responsibilities
  2. Eligibility requirements for the ICHRA
  3. Effective dates of participation
  4. Description of benefits provided and excluded
  5. How the ICHRA is funded and how it makes payments
  6. Claims procedures
  7. HIPAA privacy officers and rules relating to the use of protected health information (PHI)
  8. Information on federal mandates
  9. The procedure for amending the plan
  10. The procedure for plan termination

Plan Summary

Employees must be provided a written notice in the form of a Plan Summary. The Plan Summary is a condensed, user friendly explanation (psst: go easy on the legal-ease!) of the ICHRA benefit and how it works. This is a great place to include information on the different classes of benefits and a helpful link to the Take Command Health platform if employees need help choosing the most affordable plan based on their unique needs, doctors, prescriptions, etc. Giving employees as many resources up front will ease the transition, especially if they are shopping on the individual market for the first time.

ICHRA Employee Notice

Since the Individual Coverage HRA requires employees to purchase an ICHRA qualified plan for themselves (as opposed to picking a tier option from an employer sponsored group health plan), the employee notice is designed to guide employees in the process of purchasing health insurance from the marketplace which can be confusing if they haven't done so before. ICHRAs must provide a 90 day notice to eligible employees regarding the ICHRA and its interaction with premium tax credits and of the qualifying 60 day Special Enrollment Period (SEP) that is activated when an employee gains access to ICHRA.

The ICHRA Employee Notice will need to include the following information:

  1. Permitted benefit amount per employee & ICHRA start date for employee.
  2. An opt-out provision for the employee
  3. An explanation of potentially utilizing a premium tax credit if the employee opts out of ICHRA and the ICHRA allowance is deemed unaffordable.
  4. An explanation of what happens with the premium tax credit if the employee accepts to participate in ICHRA.
  5. The employee will need to inform the health insurance Exchange of ICHRA if they apply for APTC.
  6. A statement that ICHRA is not QSEHRA.
  7. Contact Information for employees to contact for help regarding their ICHRA.
  8. Statement that new access to ICHRA qualifies employees and dependents to a Special Enrollment Period (SEP) to purchase insurance from the Exchange for 60 days.

Check out our post on the 90 day notice for the individual coverage HRA for more information. There are also special provisions being made during the COVID-19 pandemic.

 

We are here to help!

Does this sound confusing, expensive or both? Don't worry. We are here to make your life easier. Our ICHRA administration tool makes setup a walk in the park. We handle all the accounting and legal legwork, take care of on-boarding each of your employees (or clients), and make tax time easy and painless.

Want to learn more? Check out our ICHRA guide or chat with one of our HRA experts online. We'd be happy to help!

 

 

Picture of Keely S.

Hi, I'm Keely S.! A wife to one and mother to four, Keely does all of the things. She’s also dabbled in personal finance blogging and social media management, contributed to MetroFamily magazine, and is passionate about good food, treasure hunting and upcycling. With a B.S. in Psychology from the University of Oklahoma and a knack for a witty punchline, it’s no surprise that Keely’s social posts are as clever as they get. In her (very little) free time, you’ll find Keely with her nose in a book or trying out a local restaurant with her family.