Planning to introduce ICHRA? Use this checklist to assign the work: evaluate employee impact, design the benefit, review required notices, support enrollment and confirm payments and active coverage. Dates and responsibilities must be confirmed for your actual launch.
A defensible ICHRA launch moves through feasibility, plan design, provider contracting, data readiness, required notice, employee education, individual enrollment, payroll and payment validation, and post-launch reconciliation. Skipping an earlier stage creates failures later.
Planning for 2027?Use the 2027 affordability guide and record your requirements in the evaluation brief. Keep older plan-year examples separate from current modeling.
Recommended planning window
A January 1 start aligns with annual individual-market open enrollment and common deductible resets. Existing employees generally need the required notice at least 90 days before the plan year, so a serious January launch should begin months earlier. Mid-year launches can work, but special enrollment, current group-plan termination, coverage effective dates, and employee communication require additional coordination. sourcesource
Map local individual marketsCarriers, plans, networks, prescriptions, premium ranges, and lowest-cost Silver plans.
Model contribution scenariosAffordability, employee outcomes, employer cost, and class/age/dependent variation.
Complete legal and tax reviewPlan documents, ERISA considerations, employer mandate, cafeteria plan, reporting, and state issues.
Select and contract the administratorScope, service levels, implementation, integrations, payments, security, data, and escalation.
Configure the planClasses, allowance, plan year, reimbursable expenses, carryover, eligibility, and opt-out.
Integrate HRIS and payrollEligibility feeds, deductions, reimbursement, employer contributions, terminations, and error reporting.
Deliver required noticeGenerally at least 90 days before the plan year for existing eligible employees.
Educate employeesReason for change, allowance, tax credits, plan comparison, deadlines, support, and payment.
Check the 2027 enrollment-assistance routeIdentify each employee's Marketplace platform, confirm any proposed broker's plan-year authorization, and document another route to help if needed.
Track enrollment and waiversCoverage selected, proof received, unresolved cases, special enrollment, and effective dates.
Reconcile before first paymentEmployee roster, plan premium, contribution, payroll deduction, carrier, and coverage status.
Approved plan documents, class logic, affordability analysis
Data and integrations
HR/payroll plus administrator
Validated fields, test files/API, exception handling
Employee communication
HR, broker, and administrator
Notice delivery, education materials, attendance, support plan
Enrollment and coverage
Employee with administrator/broker support
Plan confirmation, effective date, coverage substantiation
Payments and reimbursement
Administrator and finance/payroll
Reconciliation report and failed-payment procedure
Governance
Executive sponsor
Decision log, metrics, issues, corrective actions
Test failure paths before launch
An employee's insurer does not receive the premium.
A new hire's coverage effective date misses eligibility.
An HRIS termination does not reach the administrator.
An employee cannot find a critical provider or prescription.
A contribution amount is wrong for an age or family tier.
An employee expected a premium tax credit that an affordable offer blocks.
A reimbursement is denied because coverage proof is incomplete.
For each failure, define the owner, evidence required, response time, carrier interaction, employee communication, and correction record.
Launch standard
Do not call the project complete when enrollment closes.
The launch is complete only when coverage, payroll, contribution, carrier payment, and reimbursement records reconcile—and employees know where to go when the first exception occurs.
Review dates are recorded for each source above. Company pages are useful for confirming how a product is described, but they do not prove service quality or customer results.
