Yes — employers can designate a waiting period for new employees before they become eligible for an ICHRA. This is a common setup for groups that want benefits eligibility to align with sustained employment, onboarding milestones, or other internal policies.
Employers can designate waiting periods of 30, 60, or 90 calendar days or decide not to designate one at all. The waiting period must be the same for all groups eligible for your company’s ICHRA, and you cannot change your waiting period mid-year.
You can choose from several compliant waiting-period structures, including:
- First of the month after X days of service (e.g., first of the month after 30 days)
- First of the month after X months of service (commonly 60 or 90 days)
- A specific number of days, up to the ACA’s maximum waiting limit
- No waiting period (immediate eligibility)