Review employer and ICHRA records regularly rather than waiting for renewal or year-end reporting.
Look for:
Employees appearing in one system but missing from another
Unreported hires or terminations
Outdated employee classes
Incorrect effective dates
Allowance discrepancies
Incomplete enrollment
Access that is no longer required
Records to retain may include:
ICHRA notices and delivery records
Plan documents and amendments
Employee class assignments
Allowance amounts and effective dates
Eligibility determinations and effective dates
Coverage verification and carrier confirmations
Opt-out elections and waivers
Affordability determinations and supporting inputs
Employer reporting records and supporting workforce data
Correspondence documenting resolved discrepancies
Retention periods depend on the record type, applicable law, and your organization's retention policy. Confirm applicable requirements with benefits counsel.