ICHRA + QLEs + Medicare Eligibility
Key Rule:
Under IRS and HHS guidance, an employee may only newly enroll in an ICHRA (or change their election) if they experience a Special Enrollment Period (SEP) triggered by a Qualifying Life Event (QLE).
One of the recognized QLEs is gaining eligibility for Medicare (Parts A, B, or both).
What this means in practice:
If an employee did not elect ICHRA during their initial enrollment window, but later turns 65 and becomes newly eligible for Medicare, that does count as a QLE.
The QLE provides a 60-day special enrollment window beginning on the date of Medicare eligibility.
During that SEP, the employee may elect ICHRA and receive reimbursements for Medicare premiums (and other eligible expenses, depending on plan design).
Important caveats:
Simply turning 65 without enrolling in Medicare is not enough — the QLE is triggered by actual eligibility for and enrollment into Medicare.
If someone was already Medicare-eligible before the ICHRA plan year began and declined ICHRA, they may not get a new SEP just because of age. The SEP applies only at the moment of initial Medicare eligibility.
✅ Answer:
Yes — under ICHRA rules, gaining eligibility for Medicare at age 65 is a Qualifying Life Event (QLE). This allows the employee to enroll in ICHRA at that time and receive reimbursement for Medicare premiums, even if they did not elect ICHRA during their initial enrollment.
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