Many use Open Enrollment to distribute the mandated annual notices. Â One that may fall off the radar is including the ICHRA Model Notice, if applicable:Â
What is ICHRA and the purpose of the Notice?
Individual Coverage HRA (ICHRA) is an employer-funded benefit, providing employees with a tax-free monthly allowance to purchase their own individual health insurance that is ACA-compliant.
The Departments of Labor, Treasury, and Health and Human Services issue the DOL Individual Coverage HRA (ICHRA) Model Notice. The DOL states that using the model notice, when completed with employer-specific information and provided on time, constitutes good-faith compliance with the ICHRA notice requirement.
The fields for insertion with specific ICHRA information are fairly simple to complete, but plan sponsor-specific.
Template Available:Â
The DOL provides the model notice template: Individual Coverage HRA Model Notice
[Wrangle will add the ICHRA notice to annual legal packet projects upon request and upon being given additional information related to the ICHRA as required for completion of the ICHRA notice]
Timing and delivery requirements:
Generally, the written ICHRA notice must be provided to each eligible employee at least 90 days before the beginning of the plan year.
For employees who become newly eligible during the plan year (such as new hires or employees who move into an eligible class), the notice should be provided no later than the date coverage can first take effect, or as soon as administratively practicable if 90 days’ advance notice is not possible.
And the notice must generally be distributed annually to eligible employees.
Delivery Method:Â Employers commonly satisfy this requirement by:
- Hand delivery,
- First-class mail, or
- Electronic delivery.
For electronic distribution, employers should follow applicable DOL electronic disclosure standards and maintain records demonstrating that the notice was furnished to employees.
- As a best practice, employers should retain evidence of distribution (such as mailing records, email transmission records, or electronic acknowledgment where available).
Other key reminders:Â
If the ERISA – ICHRA plan has 100 or more enrolled, it would require a Form 5500 report.
Other important details to know on 4th Quarter, click here to learn more.
Questions:
If you have any questions, feel free to reach out to the ERISA Desk Team at ERISADeskInfo@ascensus.com