ICHRA failure modes are rarely about the reimbursement math. They’re about notices and classes.
Employees generally must receive a detailed ICHRA notice at least 90 days before the plan year starts. For a January 1 plan year, that is October 3 — which means the boring work (class definitions, contribution methodology, affordability testing approach, sample employee communications) belongs on a spring/summer project plan, not a September scramble. New hires who become eligible later generally need the notice no later than the date ICHRA coverage can begin for them.
What the notice has to accomplish
It’s not a teaser. It has to explain how the ICHRA works, what individual coverage is required, how to claim reimbursements, and what happens with premium tax credits — in language humans can read.
May agenda for ICHRA employers
- Freeze (or knowingly revise) employee classes for the next plan year.
- Decide contribution ages/locations geography factors early enough for finance.
- Align your TPA, broker, and payroll on substantiation for premiums.
- Put the 90-day notice draft on legal review now, while there’s still oxygen.
House legislation floated in late 2025 around codifying ICHRA-like “CHOICE” arrangements made headlines, but until something is enacted and effective, administer under the current ICHRA rules. Planning is good; preemptively renaming your plan after a bill that hasn’t finished the process is not.