The answer is "YES"! If you are on Medicare or going onto Medicare and your company decides to move their company-sponsored health care plan to an Individual Coverage Health Reimbursement Arrangement (ICHRA), it can be used to reimburse premiums for Medicare and Medicare supplemental health insurance (Medigap), along with other medical care expenses. To qualify for an ICHRA, the employee that is on Medicare or is eligible for Medicare must have coverage of Part A and Part B together or Part C. Part B by itself doesn't qualify as Minimum Essential Coverage. Premiums for Parts A, B, C, D, and Medigap policies are all eligible for reimbursement.

Generally, the employer has the discretion to choose which medical expenses such as, premiums, cost-sharing, or qualified medical expenses, are eligible for reimbursement under the terms of an ICHRA. Meaning as long as the employer offers the same benefits, on the same terms and conditions, to groups of employees in specified ICHRA classes, as stated in the exceptions under the same terms requirement in the final rules.

Here's another thing to remember as well. ICHRA can pay for medical expenses for Medicare participants (if allowed by the plan) but medical expenses cannot be designed around what Medicare pays or does not pay. This is a very important rule to remember!