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What Happens to ICHRA When You Leave Your Job?

Leaving a job with ICHRA? Check when reimbursements end, how to keep your individual policy active, and whether you can change plans or get Marketplace savings.

Quick answer

Leaving a job can end your employer’s ICHRA reimbursements while your individual health insurance stays active. Confirm the last day of reimbursement coverage with HR, then ask your insurer who will pay the next bill and when it is due. source source

Get three dates in writing

  1. Last day of ICHRA coverage. Ask HR or the administrator for the exact date for you and any family members covered by the arrangement. Your last day at work may be different.
  2. Deadline to file remaining claims. Ask which expenses you can still submit, how to send receipts and proof of coverage, and how to do it if you lose access to your work login.
  3. Next insurance premium due date. Ask the insurer whether your policy is active, which month is paid through, and what you owe next. If the employer or administrator paid the insurer, ask how to switch to paying the insurer yourself.

Keep your insurance active while you decide

Your individual policy and your employer’s reimbursement arrangement are separate. If you keep your policy, confirm the new payment method with the insurer and make the next payment by its due date. For example, if the administrator confirms it paid your November premium and will stop there, check with the insurer that November was credited and get the amount and due date for December. source source

If you switch to a new employer plan, a family member’s plan or another Marketplace policy, confirm the new coverage start date before ending your current policy. Check each family member’s coverage as well.

File eligible claims before the deadline

The date you incurred an expense and the deadline to submit it are different. Ask how to file expenses you incurred while you were covered by the ICHRA, even if the bill or reimbursement comes after you leave. The administrator can confirm what qualifies, how much remains available, and what proof it needs. Future expenses require continued eligibility under the employer’s plan or an available continuation option. An unused allowance is a limit on reimbursements, so don’t include it as cash in your budget. source

Check Marketplace enrollment and savings

Losing ICHRA coverage when you leave a job may qualify you for a Marketplace Special Enrollment Period even if your individual policy stays active. For a qualifying loss, the usual window is 60 days before or after the loss. Ask your Marketplace to confirm eligibility, documentation and the start date before making a change. Keep paying your current premium while you sort out the transition. source source

If you use the Marketplace, report the end of your ICHRA, any new employer offer and changes to your estimated household income. The Marketplace can reassess whether you qualify for premium tax credits for future months. If your former employer offers continued reimbursements, ask how accepting them or waiving them affects that determination. Premium tax credits apply to eligible Marketplace coverage. source source

Ask what continuation would cost

If federal COBRA or a comparable continuation rule applies, you may be able to continue the ICHRA after leaving. Ask the administrator for the election deadline, the cost of continuation and the amount you could still claim. Continuing the ICHRA means continuing the reimbursement benefit. You still need qualifying individual coverage or Medicare separately. Compare the continuation cost and reimbursement amount alongside your insurance premium and any Marketplace savings you are eligible for. source source source

Still evaluating an ICHRA offer? Use the employee guide to compare coverage and costs.

Sources and evidence

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