Notices

ICHRA participants generally must receive a written notice explaining important information about the arrangement, including how the ICHRA may affect eligibility for the premium tax credit and other coverage decisions. Federal rules generally require the notice to be provided at least 90 calendar days before the beginning of each plan year for participants who are eligible at that time.

Before notices are distributed, review the information used to prepare them and confirm that it accurately reflects the ICHRA being offered.

Lirvion prepares the ICHRA notice using the employer-approved plan configuration. The employer is responsible for distributing the notice to eligible employees within the applicable timeframe.

Confirm who should receive the notice

Review the employees and other participants who are eligible for the ICHRA.

The notice requirement applies to individuals who are eligible to participate in the arrangement, including eligible former employees where applicable.

Confirm that eligibility information is current before notices are prepared or distributed.

Review notice timing

For participants who are eligible at the beginning of the plan year, the written notice generally must be provided at least 90 calendar days before the beginning of that plan year.

For an individual who becomes eligible later, such as a newly eligible employee during the plan year, the notice generally must be provided no later than the date the ICHRA may first take effect for that participant.

Because timing can vary based on the participant's circumstances, review notice timing whenever eligibility changes.

Confirm plan and allowance information

Review the employer and ICHRA information included in the notice.

This may include the plan year, effective date, eligibility information, available allowance, and other plan-specific information employees may need when evaluating individual health coverage.

If the ICHRA design or allowance amounts change before notices are distributed, confirm that the notice information is updated accordingly.

For more information about contribution configuration, see Allowances.

Review information about individual coverage and premium tax credits

ICHRA notices include information intended to help employees understand the relationship between the ICHRA offer, individual health insurance coverage, and eligibility for a premium tax credit through an Exchange.

Before distribution, confirm that the notice contains the required information applicable to your arrangement and that employer-specific details are complete.

The federal model notice may be used to satisfy the notice requirement when it is completed and provided appropriately, but use of the model notice is not mandatory.

Review notices when plan information changes

Changes to plan timing, eligibility, employee classes, allowance amounts, or other relevant terms may affect information previously prepared for employees.

When material plan information changes, review whether notices or other employee communications need to be revised or provided again.

Do not assume that an administrative update by itself satisfies any applicable notice requirement.

Complete your notice review

Before completing your notice review, confirm that:

• Eligible participants have been identified.

• Required notice timing has been reviewed.

• Employer and plan information is accurate.

• Eligibility information reflects the current plan design.

• Allowance information is correct.

• Required information concerning individual coverage and premium tax credits is included.

• Your team has a process for reviewing notices when relevant plan information changes.

Once these items are confirmed, your notice review is complete.

Important: This article provides general administrative information about ICHRA and does not constitute legal, tax, or accounting advice.

Consult your legal, tax, benefits, or other qualified professional regarding notice requirements applicable to your organization.