When you offer an ICHRA to your employees, you automatically trigger a Special Enrollment Period (SEP) that allows employees to shop for and enroll in individual health insurance plans outside of the traditional Open Enrollment window. This SEP is unique to ICHRAs and ensures employees can get coverage when their new benefit begins.
This article explains how these SEPs work and what employers should know when onboarding new hires or launching an ICHRA mid-year.
What Is a Special Enrollment Period (SEP)?
A Special Enrollment Period gives employees a limited window to enroll in individual health insurance outside of annual Open Enrollment when they experience a qualifying event.
Offering an ICHRA is considered one of those qualifying events.
When Does an ICHRA SEP Occur?
Employees receive an SEP when:
- You introduce an ICHRA for the first time
- A new hire becomes eligible for your existing ICHRA
- An employee gains eligibility due to a class change
If an employee moves into an ICHRA-eligible class, they also receive a new SEP.
How Long Does the ICHRA SEP Last?
Employees have a 60-day enrollment window:
- 30 days before the ICHRA eligibility date
- 30 days after the eligibility date
This ensures employees can have their individual coverage begin on the same day their ICHRA allowance starts.
What Employers Need to Do
As the employer, your responsibilities during an ICHRA-triggered SEP include:
- Ensuring employees receive their ICHRA notice on time
- Inviting employees to BEN360 so they can begin enrollment
- Confirming the correct eligibility date for each employee
- Communicating deadlines and answering general questions
- Reviewing participation updates via the “View All Employees” table
BEN360 and your Benafica team handle the rest — from plan shopping support to carrier submission.
Special Enrollment Periods for New Hires
New hires become eligible for the SEP based on your company’s waiting period rules.
For example:
- Start Date: June 2
- 30 days of service + “1st of the month after” rule
- Eligibility Date: August 1
- SEP Window: July 2 – August 31 (60 days total)
BEN360 calculates each employee’s window automatically.
