Open enrollment is a critical window in the U.S. health insurance calendar. It’s the one time each year when most people can sign up for or change their health insurance plans.
If you're an employer offering an Individual Coverage Health Reimbursement Arrangement (ICHRA)—or an employee using one—understanding how open enrollment works is essential.
In this guide, we’ll answer:
What is open enrollment?
When is open enrollment?
How open enrollment applies to ICHRAs
What to do if you miss it
And how employers can plan ahead
Let’s get into it…
What is open enrollment?
Open enrollment is the annual period when individuals can enroll in a health insurance plan, switch plans, or apply for premium subsidies. It applies to:
Health insurance plans purchased through the federal or state marketplaces (like Healthcare.gov)
ICHRA users, who must be enrolled in a qualified individual health plan to receive reimbursements
Most job-based and COBRA plans
If you don’t sign up during open enrollment, you’ll need to wait until next year—unless you qualify for a Special enrollment Period (SEP) triggered by a life event like marriage or losing other coverage.
When is open enrollment for 2026?
Start: November 1, 2025
End: January 15, 2026
Coverage start dates can differ depending on when employees enroll. Learn more in our guide to open enrollment. You can also go to Healthcare.gov for more info and fine print on open enrollment dates and deadlines.
How open enrollment affects ICHRAs
If your employer offers an ICHRA (Individual Coverage HRA), you must be enrolled in a qualified individual health plan to receive tax-free reimbursements.
This means open enrollment is your opportunity to secure coverage that makes your ICHRA usable. If you miss it, you may lose access to your employer's contribution for the rest of the year.
To use an ICHRA, your health plan must be:
Individual (not a group plan)
ACA-compliant (covers essential health benefits)
ICHRA and special enrollment periods (SEPs)
Good news: if your employer offers you an ICHRA outside of open enrollment, that offer triggers a 60-day Special enrollment Period.
This SEP lets you shop for a qualified individual plan even if open enrollment is closed.
You typically have 60 days prior to the ICHRA start date to enroll in individual coverage.
If you don’t enroll in time, you may have to wait until the next open enrollment window.
What happens if you miss open enrollment?
If you miss both open enrollment and your ICHRA-triggered SEP, you typically won’t be able to enroll in a qualified plan until the next open enrollment period.
That means:
You can't use your ICHRA to get reimbursed for premiums or medical expenses
You may want to seek alternative short-term coverage
Your employer can’t make tax-free reimbursements until you’re enrolled in eligible coverage
Exceptions include triggering another SEP (marriage, birth, job loss, etc.), but those are case-specific.
Tips for employers offering ICHRAs during open enrollment
If you're an employer planning to offer an ICHRA for the first time or renewing your ICHRA strategy, keep the following in mind:
Best practices:
Time your offer before open enrollment (ideally in October) so employees can shop early
Educate employees on how to enroll in a compliant plan through the marketplace or private channels
Use a platform like Thatch to automate notice delivery, eligibility tracking, and reimbursement compliance
Encourage employees to opt into automatic re-enrollment where available
Employers are required to provide a formal notice to employees at least 90 days before the plan year begins when offering an ICHRA. Source: 45 CFR 146.123(c)(6) What proof do I need to use the ICHRA Special Enrollment Period?
To take advantage of the 60-day Special Enrollment Period (SEP) triggered by an ICHRA offer, you’ll need to provide documentation to the health insurance exchange or insurer. This step is essential—without proof, your SEP application could be delayed or denied.
What counts as proof?
A formal ICHRA offer notice from your employer
Documentation showing the date you became eligible for the ICHRA, any official communication that confirms your eligibility and the start date of your ICHRA benefit
Most healthcare exchanges and health benefits administrators (including Thatch) will provide instructions on how to upload or submit these documents during the enrollment process. Be sure to keep a copy of your ICHRA offer notice and respond promptly if the exchange or your benefits administrator requests additional information.
Tip: If you’re unsure what’s required, check with your employer, benefits administrator, or the health insurance exchange before your SEP window closes.
Common ICHRA Enrollment Pitfalls (and How to Avoid Them)
Even with the flexibility of open enrollment and SEPs, it’s easy to make mistakes that can jeopardize your coverage. Here are common pitfalls—and how to avoid them:
Missing deadlines: The SEP window is only 60 days. Mark your calendar and act quickly when you receive your ICHRA offer.
Not providing documentation: Failing to submit proof of your ICHRA offer can result in a denied application. Gather and upload your documents as soon as possible.
Choosing the wrong type of plan: Only ACA-compliant individual plans qualify for ICHRA reimbursement. Double-check that your chosen plan meets these requirements.
Assuming group plans are eligible: Coverage through a spouse’s employer or other group plans does not qualify. You must enroll in your own individual plan.
Overlooking renewal requirements: Even if you already have a plan, you must re-enroll or confirm your coverage each year during open enrollment to keep your ICHRA eligibility.
Bottom line: Stay organized, read all notices carefully, and ask questions if you’re unsure. Planning ahead helps you avoid coverage gaps and maximizes your ICHRA benefit.
FAQs about open enrollment and ICHRAs
Can I use my ICHRA if I don’t enroll during open enrollment? Only if you qualify for a Special enrollment Period triggered by the ICHRA offer or another life event. Otherwise, you’ll have to wait until the next open enrollment period.
Can my employer require me to use a certain insurance company? No. ICHRAs must allow employees to choose from any ACA-compliant individual plan on or off the exchange.
Can I use an ICHRA with a spouse’s group plan? No. You must be enrolled in an individual health plan. Group coverage does not qualify.
Do I need to re-enroll every year? Yes. Even if you're already using an ICHRA, you must confirm or renew your individual coverage during open enrollment to stay eligible for reimbursements.
Final takeaways
Open enrollment is the one guaranteed time each year when individuals—including ICHRA users—can enroll in a qualified health plan.
ICHRAs require ACA-compliant individual coverage, which means enrolling during open enrollment is essential unless you qualify for an SEP.
Employers offering ICHRAs should coordinate communications and support around this timeline to avoid coverage gaps.
By planning ahead and understanding how open enrollment connects to your ICHRA strategy, both employers and employees can avoid last-minute stress—and maximize the value of this modern health benefit.
Resources for further reading
Healthcare.gov: Open Enrollment Dates
IRS: Publication 969 (HRAs)
CMS: ICHRA FAQ Document
