ICHRA Special Enrollment Period (SEP)

ICHRA Special Enrollment Period (SEP): Definition & Timeline

An ICHRA Special Enrollment Period (SEP) is an ACA-mandated 60-day window triggered when an employer first offers an Individual Coverage Health Reimbursement Arrangement or an employee becomes newly eligible. It permits employees to purchase individual health insurance on public or private exchanges outside the standard annual Open Enrollment.

Key SEP Timelines

• 60 Days Prior: Employees may enroll in an individual policy up to 60 days before the ICHRA benefit start date.
• 60 Days Post-Trigger: Employees have up to 60 days following the date their ICHRA coverage becomes effective to select and bind coverage.
• Loss of Minimum Essential Coverage (MEC): When leaving group coverage to enroll in an ICHRA, the loss of prior qualifying group health plans triggers a standard federal qualifying life event (QLE).

Employer Notice Obligations (90-Day Requirement)

Under federal regulations (26 CFR § 54.9802-4), employers must deliver a formal written ICHRA Notice at least 90 days before the start of each plan year. For newly hired or newly eligible employees, notice must be provided no later than the date coverage begins.

SimplyHRA automates this entire regulatory workflow, generating compliant 90-day notices, calculating individual affordability, and issuing employee SEP certification documentation directly to carriers and exchange portals.