Why don't dual coverage rules apply to employees with an ICHRA and Medicare?

Answer:

An ICHRA is NOT a group health insurance plan. Instead, it is a tax-free reimbursement arrangement that helps pay for eligible individual health insurance premiums, including Medicare.

Because your ICHRA does not provide health insurance coverage, it does not coordinate benefits with Medicare like a traditional employer-sponsored group health plan. Medicare remains your primary coverage, and the ICHRA simply reimburses eligible expenses as allowed by your employer's plan.

In short, there are no dual coverage or coordination of benefits issues between Medicare and an ICHRA because the ICHRA is a reimbursement arrangement, not insurance.