July 17, 2023

Did you miss the May 31 individual coverage health reimbursement arrangement (ICHRA) webinar? If so, no worries! Join us for a four-part series called "ICHRA — Navigating for Success."

Part 2: Entity Eligibility | ICHRA 90-Day Notice | Individual Plan Substantiation

Entity eligibility — corporate structures

ELIGIBLE

• C corporations 
• B corporations 
• Nonprofits
• LLCs (taxed as a C corporations) 

NOT ELIGIBLE

• Partnerships
• S corporations
  • (Owners — and their spouses — who own more than 2 percent of the business cannot participate in an ICHRA. However, the employees can participate. Owners can remain on the list bill at the full premium.)
• Sole proprietorships

ICHRA 90-day notice — find a model notice at www.CMS.gov

To ensure compliance, the ICHRA 90–day notice is due from the employer to the employee at least 90 days before the beginning of the ICHRA plan year. 
 
Employees who become eligible for an ICHRA during the plan year or later than 90 days before the start of the ICHRA plan year (e.g., new hires) should get their notice no later than their coverage effective date under the ICHRA. 

The Centers for Medicare & Medicaid Services (CMS) is an independent organization that offers health information you may find helpful.

Individual plan substantiation — required for the release of health reimbursement arrangement (HRA) funds

Download the infographic here.

Automatic substantiation for BlueCross BlueShield of South Carolina Medicare Supplement plans requires 100 percent premium coverage by the HRA contribution.

Individual Plan Substantiation — ICHRA and Medicare Part B

MEDICARE PART B
Individuals must submit proof of enrollment and payment for Medicare Part B substantiation. One exception is if the individual’s premiums are deducted from his or her Social Security. If so, BlueCross requires the ICHRA Medicare Part B Reimbursement Request Form for substantiation. 

Please contact your sales representative if you have questions or need more information.