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9 Important ICHRA Dates for Brokers to Know


If you’re a trusted resource for clients, you’ll stand out in the broker world. Knowing key health insurance dates, as well as the compliance implications, will help you support your portfolio of companies as they navigate the ever-changing world of health plans. 

Some of the dates below are specific to ICHRA. Others are for the Health Insurance Marketplace and are relevant because employees buy their health plan through the marketplace when their employer has an ICHRA. 

Bookmark this page as your broker health insurance calendar, and connect with Take Command anytime you have questions.

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Health Insurance Calendar: Important Dates and Timelines

Event Date/Timeline
ICHRA plan year
The 12-month date range when a company’s ICHRA plan begins and ends

(Note: Employers get to choose their ICHRA plan start date; it can happen any time of year and will trigger a special enrollment period so your employees can find plans on the individual market outside of the open enrollment dates.)

Dates are set by employer; after the initial implementation, the ICHRA plan year follows the ACA schedule
Marketplace Open Enrollment

Federal marketplace open enrollment
Federal timeline when employees can enroll in a health insurance plan through the marketplace

State-specific marketplace open enrollment
State-specific timelines when employees can enroll in a health insurance plan through the marketplace

Nov. 1–Jan. 15

Many states follow the federal open enrollment dates, but these states have their own schedule: California, Colorado, Connecticut, Idaho, Kentucky, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Jersey, New Mexico, New York, Pennsylvania, Rhode Island, Vermont, Virginia, Washington DC, and Washington state

Medicare open enrollment
When employees can enroll in Medicare
Oct. 15–Dec. 7
ICHRA plan documentation
When an employer establishes their company’s ICHRA guidelines, including definition of eligibility, reimbursement amounts, and claims processes
Ideally 90–120 days before the plan year starts
Employee notice 
When an employer sends a notice to employees about their ICHRA plan
At least 90 days before the plan year starts
ICHRA special enrollment
An ICHRA special enrollment is triggered by 1) An employee’s qualifying life event such as marriage or birth of a child or 2) When an employer starts offering an ICHRA
Employee has 60 days to sign up for a health plan
Form 1095-C filing 
The IRS form for employer-provided health insurance; applies only to applicable large employers
  • IRS electronic filing deadline: Usually March 31 (for prior calendar year)
  • IRS paper filing deadline: Usually February 28
  • Due to employees: Usually March 2
PCORI filing
Patient-Centered Outcomes Research Institute fees and IRS form 720
July 31 of the following calendar year
Broker license renewal
The mandatory process a broker must complete to maintain their active license and continue practicing
Varies by state; often coincides with broker’s birth month

Client reviews
An opportunity for brokers to check in with clients and evaluate their benefits package

  • Clients with group insurance: Assess satisfaction level and interest in adding an HRA to their group insurance mid-year or switching to ICHRA
  • Clients with ICHRA: Assess satisfaction level and discuss any desired adjustments to contribution rates, employee classes, etc.
Recommended annually or quarterly

Who makes the rules for health insurance compliance?

There are three governing bodies for ICHRA. The IRS oversees compliance and reporting. The Department of Labor governs plan documentation and employee notices. Health and Human Services is in charge of special enrollment periods.

Health insurance dates are an important part of compliance because employers are required to submit paperwork, send notices, and file legal documents within designated timeframes. Understanding the compliance landscape will make you better support clients stand out among your peers.

Key ICHRA Regulatory Requirements

How Take Command Helps

Take Command was the first-to-market ICHRA leader, so we know the ropes. Our expertise is backed by our ICHRA administration platform, which has built-in, automatic updates to ensure compliance and provides all necessary ICHRA plan documents for both employers and employees.

We’re also an industry leader in customer support, so if you or your clients have questions, we’re an excellent resource.

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Health Insurance Calendar FAQ

Does ICHRA have its own set of dates and deadlines?

Yes, ICHRA has its own set of dates and deadlines. Some are specific to ICHRA, such as the plan date and employee notice deadlines. There are other deadlines for health insurance generally which apply to ICHRA as well.

What happens if you miss a deadline?

There are varying consequences for missing different ICHRA deadlines. If an employer is out of compliance for health coverage, they could face financial penalties, government investigations, or even a lawsuit. But your ICHRA administrator should provide tools to help keep them compliant.

What are the most important ICHRA dates to know? 

All ICHRA deadlines are important, but if all those dates feel overwhelming, read about ICHRA plan documentation first, which will give you a great start.

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