Eligibility Updates

Learn how to report employment and family changes that may affect an employee’s or dependent’s ICHRA eligibility.

Sep 11, 2026

Eligibility updates occur when a change in employment or family circumstances may affect whether an employee or dependent can participate in the employer's ICHRA. Reporting these changes promptly helps keep eligibility information consistent with the employer's plan terms and applicable effective dates.

An update may result from a new hire completing a waiting period, a change in employment status or employee class, a leave of absence or return to work, employment termination, or a change in dependent eligibility. A newly eligible employee or dependent may need to act within a limited enrollment period to obtain or update qualifying individual health insurance coverage.

Employers should provide the applicable effective date, employee class, employment status, work location, and any requested supporting information. Eligibility rules should be applied consistently to employees within the same class.

Eligibility updates may also affect information or actions addressed in Employee Changes, Allowances, and Enrollment.

Employers remain responsible for employee classification, eligibility decisions, the accuracy of submitted information, and required employee notices.

This information is provided for general administrative purposes and is not legal or tax advice. Employers should consult qualified legal, tax, or benefits professionals regarding employee classifications, waiting periods, eligibility determinations, notice obligations, and enrollment deadlines.