Renewal

Learn what employers should review before renewing an ICHRA for a new plan year and which plan, employee, and administrative details may need to be updated.

Sep 7, 2026

ICHRA renewal is an opportunity to review whether the arrangement still reflects your organization’s workforce, contribution strategy, and administrative requirements for the upcoming plan year.

Before the new plan year begins, review the plan design, employee data, allowance amounts, affordability considerations, required notices, and other records used to administer the ICHRA.

Review plan-year dates and plan design

Confirm the upcoming plan year, effective date, and any changes to the structure of the ICHRA.

If your organization is changing eligibility rules, employee classes, contribution amounts, or other plan terms, make sure those decisions are reflected consistently in the plan setup and related documentation.

For more information about plan documentation, see Documents.

Review employee eligibility and classes

Review the workforce that will be eligible for the ICHRA in the upcoming plan year.

Confirm that employee status and class assignments reflect the plan design being renewed and identify any workforce changes that may affect eligibility.

Review allowance amounts

Confirm the employer allowance amounts that will apply for the new plan year.

Changes in benefit strategy, workforce structure, individual-market premiums, or employer budget may affect the contribution amounts selected for renewal.

If different employee classes receive different allowance amounts, confirm that the renewed structure is consistent with the intended plan design.

For more information about contribution configuration, see Allowances.

Review affordability for the new plan year

Applicable Large Employers should review affordability using the information and assumptions applicable to the upcoming plan year.

Employee age, location, allowance amounts, applicable lowest-cost silver plan premiums, and the affordability methodology used by the employer can affect the result.

Because benchmark premiums and applicable affordability thresholds can change from one plan year to the next, do not rely solely on the prior year’s affordability review.

For more information, see Affordability.

Review employee notices

Confirm that required employee notices for the upcoming plan year are prepared using current employer, plan, eligibility, and allowance information.

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.

For more information about notice requirements and timing, see Notices.

Review coverage and enrollment changes

Employees may select different individual health coverage for the new plan year or experience other changes that affect ICHRA participation.

Review whether participating employees have the coverage information needed for the upcoming plan year and identify any records that require updated verification.

For more information about employee coverage review, see Coverage Verification.

Review administrative reporting and unresolved items

Before renewal is completed, review administrative records for outstanding issues from the current plan year.

This may include unresolved eligibility records, class discrepancies, allowance issues, coverage verification items, payment exceptions, or other administrative follow-up.

Renewal is a useful point to resolve known discrepancies before the next plan year begins.

For more information, see Reporting.

Complete your renewal review

Before completing your renewal review, confirm that:

  • The upcoming plan year and effective date are correct.

  • Any plan design changes have been reviewed.

  • Employee eligibility and class assignments are current.

  • Allowance amounts have been approved for the new plan year.

  • Affordability has been reviewed where applicable.

  • Required employee notices are being prepared using current information.

  • Coverage and verification records that need renewal-year updates have been identified.

  • Outstanding administrative items from the current plan year have been reviewed.

  • Your team understands which plan and workforce changes may require additional action before the new plan year begins.

Once these items are confirmed, your renewal review is complete.n about ICHRA and does not constitute legal, tax, or accounting advice.

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 renewal requirements applicable to your organization.