By Andy Stein, Founder & President, The Worksite Group
Two recent news stories (one from Politico and one from the Ohio Statehouse) paint a clear message: ICHRA isn’t a trend. It’s becoming infrastructure. For benefits brokers who aren’t yet fluent in ICHRA administration, the window to get ahead of this is narrowing.
We’ve helped brokers with more than 250 implementations. Here’s what the current landscape means for your ICHRA administration strategy and your practice.
Why ICHRA Policy Is Sticking
ICHRA was created through a Trump administration final rule in 2019. The Biden administration could have reversed it and chose not to. Now, Republicans and Democrats at the state level are actively competing to build on it. That bipartisan staying power is the single most important thing to communicate to a skeptical client.
A recent Politico report documented at least six states, including Republican-led Ohio and Democratic-led Connecticut, pursuing ICHRA tax credit legislation. Republicans like it because it puts health dollars directly in the hands of consumers. Democrats like it because it channels workers into ACA marketplace plans and keeps people off Medicaid. Both sides are moving in the same direction.
“Everyone, whether Republican or Democrat, is just looking for solutions to get as many folks covered as possible.” — William Melofchik, CEO, National Conference of Insurance Legislators
The practical upshot for brokers: when a client raises the “what if this goes away” objection, the answer has never been stronger. ICHRA has now passed the House of Representatives twice in codification legislation, and a National Conference of Insurance Legislators (NCOIL) model bill could go to a vote as early as April 2026, potentially triggering adoption across dozens of additional statehouses.
The State Tax Credit Conversation You Should Be Having Now
If your clients are in Indiana, Ohio, Mississippi, or Wisconsin, there is a new and immediate financial argument for ICHRA that didn’t exist 12 months ago.
Indiana’s enacted law offers a $400 per-employee tax credit in year one and $200 in year two for employers with fewer than 50 workers. Ohio’s House Bill 133 passed the House unanimously and awaits Senate action. Mississippi crossed both chambers in February 2026. Wisconsin passed its Assembly in February 2026. Connecticut’s Democratic governor included an ICHRA tax credit in his 2026–27 budget request.
For a 30-person company in Indiana, that’s up to $12,000 in year-one tax relief. That’s not a long-term benefits strategy argument. That’s a number you can put in front of a CFO today.
The Market Context Driving Demand
The economic conditions for ICHRA conversations have rarely been better. The KFF 2025 Employer Health Benefits Survey found average family premiums hit $26,993, up 6% year over year, the third consecutive year of 6%+ increases. Mercer projects average employer health costs will exceed $18,500 per employee in 2026. Employers are hurting, and they’re looking for alternatives.
At the same time, the expiration of enhanced ACA subsidies at the end of 2025 has pushed marketplace enrollment down by more than one million people, according to KFF. Employers with uninsured workers are scrambling for coverage solutions. ICHRA is near the top of that list.
Adoption is following that demand. The HRA Council’s 2024–2025 Growth Trends report puts total ICHRA and QSEHRA enrollment between 500,000 and 1 million people, over 1,000% growth since 2020. Large employer adoption grew 34% year over year, with some cohorts hitting 49%. And 83% of new ICHRA adopters had never previously offered health coverage at all. This market isn’t just shifting. It’s expanding.
What to Look for in ICHRA Vendors (and Why It Matters for Your Book)
According to a 2025 Zorro survey of 100+ group benefits brokers, 93% expect ICHRA adoption to increase over the next five years. More than 50% are already selling it. And 87% reported having lost a client by not presenting ICHRA as an option. That last number is the one worth sitting with. And with more ICHRA vendors entering the market, the brokers who know how to evaluate them are the ones clients will trust to lead the way.
Here’s what the current environment means for you:
- Clients facing brutal renewals are ready for a different conversation. ICHRA’s defined contribution model gives employers cost predictability and transfers renewal risk off their books entirely.
- The “it might go away” objection has a strong answer now. Bipartisan state legislation, two House codification passes, and growing insurer investment all point to long-term durability.
- State tax credits are a near-term financial argument in multiple states right now, with more coming. It’s a number to put in front of a CFO, not just a concept to explain to HR.
- Employers who never offered benefits before are increasingly reachable. 83% of new ICHRA adopters came from no prior coverage. Those are clients who may never have seen you as relevant until now.
Be Honest With Clients About the Limitations
ICHRA is a strong tool for the right employer. It’s not the right tool for every employer, and presenting it as such sets up credibility problems down the road.
The core risk is cost-shifting. Employers lock in a fixed contribution while premiums keep rising. If the allowance doesn’t keep pace, employees absorb the difference. The Peterson-KFF Health System Tracker notes that lower-income employees may actually fare better with ACA marketplace subsidies than with a modest ICHRA contribution, since an “affordable” ICHRA offer blocks access to those credits entirely.
Individual market networks are also narrower than group plans in many markets, typically HMOs and EPOs with no out-of-network coverage. Employees accustomed to PPO access need to understand what they’re trading. One employer cited by KFF saw satisfaction drop from 95% to 89% in their second year, not because the model failed, but because employees didn’t know how to shop for their own plan.
That last point is why ICHRA administration quality matters as much as the product itself. Not all ICHRA vendors approach implementation the same way. The ones who hand over a platform login and disappear leave employees confused and HR overwhelmed. The ones who pair technology with licensed benefit counselors and year-round support get a very different result. If you want to see how we handle that side of the equation, take a look at how we approach ICHRA administration.
The Bottom Line
Both parties are moving toward ICHRA. State legislatures are building financial incentives around it. Employer health costs are at a 20-year high. And 87% of brokers who didn’t present it lost a client over it.
This is the environment you’re operating in right now. The brokers who understand ICHRA deeply, who can present it credibly and implement it well, are the ones winning clients that others aren’t even in the room for. If you’re ready to add that capability to your practice, here’s how we work with brokers on ICHRA administration.
If you’re not yet having these conversations, the question is: what are you waiting for?
Ready to talk through ICHRA opportunities for your book of business? Let’s connect.
— Andy Stein, Founder & President, The Worksite Group


