What documentation do employees need to provide to receive reimbursement?

What documentation do employees need to provide to receive reimbursement?

What documentation do employees need to provide to receive reimbursement?

To receive ICHRA reimbursements, employees must substantiate their expenses by providing documentation that verifies they meet eligibility requirements and have incurred qualified expenses. This is a legal requirement—employers cannot simply take employees at their word.

Proof of individual health coverage

Before any reimbursements can be made, employees must provide proof that they are enrolled in individual health coverage that qualifies as minimum essential coverage (MEC). Acceptable documentation typically includes:

  • Insurance card showing the employee's name and coverage effective date
  • Certificate of coverage from the insurance carrier
  • Explanation of Benefits (EOB) statement
  • Official documentation from the marketplace showing enrollment
  • Premium invoice or billing statement from the carrier

This verification must occur before the first reimbursement is issued and may need to be repeated periodically—such as at the start of each plan year or when coverage changes.

Documentation for premium reimbursement

When submitting claims for premium reimbursement, employees generally need to provide:

  • Proof of premium payment (bank statement, credit card statement, or carrier receipt showing payment)
  • Premium invoice or billing statement showing the amount due, coverage period, and covered individuals
  • Evidence that the coverage is MEC-qualifying (if not already established)

Documentation for other qualified medical expenses

If the employer's ICHRA plan allows reimbursement for expenses beyond premiums, employees must provide documentation for each expense, including:

  • Itemized receipt or invoice showing the date of service, provider name, description of service, and amount
  • Explanation of Benefits (EOB) from the insurance carrier, if applicable
  • Proof of payment showing the employee paid the expense out of pocket

Generic credit card statements or canceled checks alone are typically not sufficient—the documentation must show what the expense was for, not just that a payment was made.

Dependent documentation

If the ICHRA covers dependents, employees may also need to provide:

  • Proof of dependent status (such as a marriage certificate or birth certificate), typically collected at enrollment
  • Proof that each dependent is enrolled in MEC-qualifying coverage
  • Separate substantiation for any dependent-related expenses being reimbursed

How documentation is submitted

The submission process depends on how the employer administers their ICHRA. Many employers use a third-party ICHRA administrator that provides an online portal or mobile app where employees upload documentation and submit claims. Others may manage the process internally with manual submissions.

Regardless of the method, employees should keep copies of all submitted documentation for their personal records.

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