ICHRA Implementation Guide
Implementing an ICHRA requires careful planning, the right administration platform, and clear communication with employees. The critical path runs from plan design through employee notice (required 90 days before the plan year) to individual market open enrollment. Here is the full implementation timeline and the five key decisions that determine whether the launch succeeds.
The 90-day notice deadline is the critical path constraint
For a January 1 plan year, the employee notice must be delivered by October 3. That means the plan design, reimbursement amounts, and HRA administrator selection must all be finalized before October. Employers who start the implementation process in November are already behind. Plan the entire implementation timeline backward from the notice deadline.
ICHRA implementation timeline
Eight steps from plan design to annual renewal. Steps 1 and 2 must be completed before the 90-day notice deadline. Steps 3 through 5 run in parallel with the individual market open enrollment period.
Design the ICHRA
90+ days before plan yearDecide which employee classes will be offered ICHRA, set reimbursement amounts by class and family status, and determine whether unused allowances will carry over. Document all decisions in a formal plan document. Run the ACA affordability calculation for each employee class before finalizing reimbursement amounts.
Select an HRA administration platform
90+ days before plan yearChoose a third-party HRA administrator to handle employee enrollment, expense substantiation, and reimbursement processing. Evaluate platforms on ease of use, cost, compliance support, and integration with your payroll system. The platform is not optional — manual substantiation is not feasible at scale.
Provide the required employee notice
90 days before plan yearDeliver the ICHRA notice to all eligible employees at least 90 days before the plan year begins (or within 90 days of hire for new employees). The notice must include the reimbursement amount, eligibility requirements, and instructions for opting out. This is a hard compliance deadline.
Employee open enrollment
60–30 days before plan yearEmployees shop for and enroll in individual health insurance plans. Provide resources to help employees navigate the individual market — marketplace plan comparison tools, broker support, or enrollment assistance. Employees who do not enroll in qualifying coverage cannot receive reimbursements.
Confirm employee coverage
30 days before plan yearVerify that employees who will receive ICHRA reimbursements have enrolled in qualifying individual coverage. The HRA administrator handles coverage verification. Employees without qualifying coverage cannot receive reimbursements — confirm enrollment before the plan year begins.
Launch reimbursements
Plan year startThe HRA administrator activates employee accounts. Employees begin submitting premium payments and qualifying expenses for reimbursement. Employer funds the HRA account as reimbursements are approved. Establish a funding cadence — weekly or biweekly is typical.
Administer and monitor
OngoingReview reimbursement requests, confirm ongoing coverage, and track spending against the annual allowance. Update employee information as life events occur (marriage, new dependents, address changes that affect rating area). Monitor for employees who lose qualifying coverage.
Renew and adjust
AnnualReview reimbursement amounts for the next plan year, run the affordability calculation for any changed employee locations or wages, provide updated notices to employees, and repeat the open enrollment process. Annual renewal is also the time to evaluate whether the ICHRA design is meeting its goals.
Five key implementation decisions
These five decisions determine the cost, complexity, and employee experience of your ICHRA. Each has tradeoffs — there is no universally correct answer, but each must be made deliberately before the plan document is finalized.
Continue learning about ICHRA
Model reimbursement amounts and check ACA affordability before finalizing your plan design.
Evaluate your ICHRA design against compliance requirements before launch.
Next step
Ready to model your ICHRA?
Use the free ICHRA calculator to model reimbursement amounts and check ACA affordability before you commit to a plan design — and before the 90-day notice clock starts.