Timing is where ICHRAs go wrong most often. Not because it's complicated — because nobody wrote down the dates. Here they are.
The sequence, from your side
- The notice arrives. Your employer must generally give you a written ICHRA notice at least 90 days before the plan year starts (or when you become eligible, if you're new). It states your allowance, whether the ICHRA is premium-only, how affordability is figured, and how to opt out.
- Your Special Enrollment Period opens. Being offered an ICHRA is itself a qualifying event on the Marketplace. Your window generally runs from 60 days before your ICHRA start date to 60 days after. Shop inside it.
- You pick a plan with an effective date that matches — or precedes — your ICHRA start date. Coverage starting late means unreimbursed months.
- You attest and enroll in the ICHRA with your employer or administrator.
- First reimbursement after your first premium and proof.
The date that matters
Your individual plan must be
active on the ICHRA start date. If your plan year is January 1, most Marketplaces need you enrolled by around December 15 for a January 1 start. If you enroll on the last day of the SEP, your coverage — and your reimbursements — may not start until the following month.
Marketplace Open Enrollment vs. your SEP
If your ICHRA starts January 1, you'll typically use regular Open Enrollment (generally November 1 – January 15, with December 15 being the usual cutoff for a January 1 start; some states differ). If your ICHRA starts any other month, or you're newly hired, you'll use the Special Enrollment Period the ICHRA offer creates. When applying, say yes to the "were you offered an HRA?" question and enter the start date — it unlocks the SEP.
Mid-year events that open a new window
- Marriage, divorce, birth, adoption
- Moving to a new ZIP code where different plans are sold
- Losing other coverage (a spouse's plan ends, a child ages off)
- Being newly offered — or losing — an ICHRA
Most give you 60 days. Report changes to both the Marketplace and your employer.
Every year after that
Individual plans typically renew automatically. Your allowance and your affordability test may change. Each Open Enrollment, re-check: is my allowance different? are my doctors still in-network? is my plan still HSA-eligible? did my premium jump? Ten minutes on the Marketplace usually answers all four.
A simple rule
When in doubt, enroll early. A plan that starts a month before your ICHRA costs you one month of premium. A plan that starts a month after costs you a month of allowance, and possibly a month without coverage.