Employees must have a qualifying form of individual health coverage to participate in an ICHRA. To prove this, the Departments of Treasury, Labor, and Health and Human Services require employees to attest they are enrolled in a qualified health plan throughout the plan year.
Employees must meet two requirements:
- Annual Coverage Substantiation: Before the first day of each plan year, employees must verify they and each eligible dependent have or will have individual coverage with MEC (minimum essential coverage), Medicare Parts A and B, or Medicare Part C for the plan year. (This requirement is met with our ICHRA HRA Model Attestations Form)
- Ongoing Substantiation: With each reimbursement request, employees must verify that they or their eligible dependent have individual health insurance coverage, Medicare Parts A and B, or Medicare Part C during the month they incurred the expense. (This requirement is met with our ICHRA Substantiation Request Form)
Forms
ICHRA HRA Model Attestations Form:
This form informs employees of their ICHRA-offered benefits and details the requirements to enroll. If the employee enrolls in the plan, they will complete this form, add demographic information for any eligible dependents, sign it, and return it to the employer. This form does not need to be returned to Ameriflex, and the employer should keep it on file.
ICHRA Substantiation Request Form:
This form should be completed for any debit card transactions for ICHRA-related expenses or manual claims submitted via email or mail. It has the employee acknowledge that the expense was incurred during a month they were covered under their individual health coverage plan. The employee should complete the form, sign it, and submit it to Ameriflex (contact information provided at the bottom of the form).
If an employee is submitting for reimbursement via the online portal or application, there is verbiage they will acknowledge before submitting their request that satisfies the ICHRA Substantiation requirement.
