If an employer ICHRA plan year begins on a date other than January 1, employees will qualify for a Special Enrollment Period (SEP) to enroll in individual health insurance coverage that aligns with the ICHRA start date. Similarly, if an employee is hired mid-year, they can likewise use a SEP to enroll in individual health insurance.
For newly eligible individuals, the SEP typically lasts for 60 days before the first day of their ICHRA coverage and 60 days after their ICHRA coverage starts. It’s important that employees enroll as soon as possible to avoid gaps in coverage and ensure the ability to use ICHRA funds.
During this SEP, employees (and their family members, if applicable) can select or change their individual health insurance plans to ensure they have coverage that qualifies under ICHRA.
To enroll through a SEP, employees may need to submit proof of the qualifying event (such as a letter confirming new ICHRA eligibility) to their health insurance carrier. The ICHRA notice letter created by Zorro and uploaded to both the admin and employee portals acts as this SEP letter.