Short answer: Before the ICHRA’s start date. Gaining access to an ICHRA opens an individual-market special enrollment period that begins 60 days before the HRA can first take effect; a plan chosen before that date starts the first of the following month, or on the start date itself when the ICHRA starts on the first of a month.
Under 45 CFR 155.420, the triggering event is the first day the ICHRA (CHOICE Arrangement) can take effect for the person, not the day the employer announces it.
- Plan chosen before the start date: coverage begins the first day of the month after the start date, or on the start date if it falls on the first of a month.
- Plan chosen on or after the start date (only possible when the window extends past it): coverage begins the first day of the month after the plan is chosen, which leaves a gap.
Example: an ICHRA starting October 1, 2026. An employee who picks a plan in September has coverage October 1. An employee who has the later window but picks on October 1 is not covered until November 1.
The 60 days after the start date are available only where the HRA was not required to give that person the 90-day advance notice, such as a mid-year new hire. Do not end the old group plan until each employee’s new policy is confirmed and the first premium is paid.