ICHRA plan documents establish the framework and guidelines for your unique plan. Every ICHRA plan is customizable to your specific business needs and budget. In the Summary Plan Document (SPD), you will define employers' and employees' rights and responsibilities, ensure compliance with regulations, and provide a clear understanding of the benefits and processes involved.
Below are the main components that should be included in each plan’s documents.
Named Fiduciaries and Plan Administrators
The plan documents should identify the named fiduciaries and plan administrators responsible for overseeing the ICHRA plan. These individuals are crucial in managing the plan's operations and ensuring compliance with relevant regulations.
The plan documents should outline the eligibility requirements for employees to participate in the ICHRA plan. This includes criteria such as the duration of employment, minimum hours worked, and any other specifications defined by the employer.
Effective Dates of Participation
The effective dates of participation specify when employees become eligible to participate in the ICHRA plan. The plan documents should communicate the timeline for employees to enroll and receive reimbursements.
Description of Benefits Provided and Excluded
The plan documents should detail the benefits the ICHRA plan provides, including the types of expenses that are eligible for reimbursement. This includes individual health insurance premiums and other qualifying medical payments. It's essential to specify any exclusions or limitations to avoid misunderstandings.
Any expense defined as a medical or dental expense by IRS Publication 502 is eligible to be covered by your plan—but as an employer, you do not need to cover it all. Liferaft will help customize your plan’s eligible expenses according to your budget and business needs.
Funding and Payment Procedures
The plan documents should outline the funding mechanism for the ICHRA plan, including the sources of funds and how the reimbursement process works. Employers need to ensure that employees are reimbursed promptly for their eligible expenses.
The plan documents should provide clear instructions on how employees can submit claims for reimbursement. This includes documentation, submission deadlines, claims review, and payment process. Transparent and efficient claims procedures are crucial for a smooth employee experience.
HIPAA Privacy Officers and PHI Rules
Protecting employees' privacy and adhering to HIPAA regulations is of utmost importance. The plan documents should designate HIPAA privacy officers responsible for safeguarding protected health information (PHI) and ensuring compliance with privacy rules.
Information on Federal Mandates
Depending on the nature of the ICHRA plan and the organization's location, federal mandates or requirements may need to be addressed in the plan documents. This ensures that the plan remains in compliance with applicable laws and regulations.
Plan Amendment and Termination Procedures
The plan documents should include procedures for amending the ICHRA plan if necessary. This allows for flexibility in adapting to changing circumstances. Additionally, there should be clear guidelines on how to terminate the plan if the need arises.