A practical ICHRA transition checklist

1. Establish the facts

• Document current benefits, employer spending, employee contributions, and renewal terms.
• Assess workforce geography, owner participation, ALE status, and contractual constraints.
• Compare feasible alternatives and employee coverage implications.

2. Design and assign responsibilities

• Confirm permitted classes, contribution amounts, covered expenses, and carryover rules.
• Select administrative and enrollment services with documented responsibilities.
• Prepare plan documents and identify applicable reporting and continuation obligations.
• Confirm secure census collection and access permissions.

3. Confirm notices and enrollment timing

The general ICHRA notice rule is at least 90 days before the plan year. Different timing applies to specified newly eligible employees and certain newly established employers. Confirm the exception rather than assuming a first-time ICHRA automatically qualifies. Individual-market enrollment windows and effective dates must also be checked for the relevant year and Marketplace.

4. Prepare employees and operations

• Deliver the required notice and practical enrollment instructions.
• Explain allowance amounts, subsidy implications, opt-out rights, and support contacts.
• Test eligibility files, reimbursement handling, and any permitted payroll deductions.
• Verify employee coverage and the first payment/reimbursement process.

5. Verify the change before ending coverage

Coordinate group-plan termination, individual-policy effective dates, and HRA eligibility. Do not cancel the existing plan based only on an intention to enroll. Confirm the actual transition requirements with the affected providers and advisors.

6. Check the first operating cycle

• Reconcile eligible employees and reimbursements.
• Resolve missing documents and payment issues.
• Review employee questions for communication gaps.
• Record lessons and set the next operating and renewal reviews.