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ICHRA Administration in 2026: What Benefits Brokers Need to Know Now

By Blog, Employee Benefits Communication, ICHRA No Comments

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

 


Employee Benefits Communication: Why It’s Your Client’s Biggest Gap and Your Biggest Opportunity

By Blog, Employee Benefits Communication, ICHRA No Comments

By Andy Stein, Founder & President, The Worksite Group

Employee benefits communication is the process of educating employees about their benefits options so they can make confident, informed decisions. When it works, employees choose the right plans, use their benefits, and feel genuinely valued. When it fails, employers waste their benefits investment, HR gets buried in post-enrollment questions, and employees feel overlooked.

Right now, it’s mostly failing.

After every open enrollment season, the same complaints surface:

“HR is still getting bombarded with questions about coverage.”

“Employees chose the wrong plans and now they’re frustrated.”

“We spent a fortune on benefits and people don’t even understand what they have.”

For benefits brokers, this gap isn’t just a problem for your clients to fix. It’s an opportunity for you to own.

The State of Employee Benefits Communication in 2026

The data on employee benefits communication is both consistent and concerning across every major industry study.

Aon’s 2024 Global Benefits Trends Study found that 73% of benefits professionals name improving employee communication as a top strategic priority. But only 33% of businesses include benefits communication guidelines in their organizational framework. Aon’s own characterization of the situation: current efforts are underwhelming, uncoordinated, and ineffective.

MetLife’s Employee Benefit Trends Study reinforces the stakes. 59% of workers say benefits were an important reason they chose their current employer. Yet half of all employees say they would feel more cared for if their employer simply improved how it communicated benefits. More than half also want personalized benefits recommendations, something almost no employer currently provides.

The consequences are measurable. Employees satisfied with their benefits are:

1.6x more likely to be productive. 1.5x more likely to be engaged at work.
1.5x more likely to stay with their employer

Benefits communication isn’t a soft issue. It directly affects retention, productivity, and the ROI your clients get from their benefits investment.

Why Employee Benefits Communication Is Getting Harder

Benefits are more complex than they’ve ever been. Employees today are asked to choose between ICHRAs, HDHPs, FSAs, HSAs, and voluntary benefits, often with limited time, limited context, and no personalized guidance.

Research from Employee Benefit News found that 20% of employees find the enrollment process confusing, and more than half would struggle to cover an unexpected $1,000 medical expense. Poor benefits literacy doesn’t just frustrate employees. It leads to underutilization, wrong plan selection, and financial stress that spills back into the workplace.

The Deskless Worker Problem

SHRM and Fidelity’s research on deskless workers identifies the communication barriers HR faces with employees who aren’t at a desk:

  • 62% of HR professionals cite limited computer access during the workday as a top barrier
  • 56% point to irregular schedules and hours
  • 55% identify lack of face-to-face communication

Despite these known challenges, 69% of HR professionals don’t adjust their benefits communication strategies for deskless employees. They keep sending emails that never get opened and posting intranet updates that never get read.

The “Caring” Gap

A survey from Aflac found that nearly half of employees don’t believe their company genuinely cares about them. One of the primary drivers: poor benefits communication and inadequate support when it matters most. Employees aren’t just looking for better benefits. They’re looking for evidence that their employer is paying attention.

What an Effective Employee Benefits Communication Strategy Looks Like

An effective employee benefits communication strategy is a planned, multichannel approach to informing and educating employees about their benefits — before, during, and after open enrollment. It goes well beyond a packet of plan documents and a single company-wide email.

Here are the core elements:

1. Multichannel Outreach That Meets Employees Where They Are

A benefits communication strategy works only if it reaches the employees it’s designed to reach. For desk-based workers, that might mean email campaigns, benefits portals, and webinars. For deskless workers: warehouse employees, drivers, field technicians, retail associates, it means text messages, printed materials, and in-person conversations. One channel is never enough.

2. A Communication Timeline That Starts Well Before Open Enrollment

Waiting until the week before open enrollment to start communicating benefits is too late, especially when employers are making plan changes. Employees need lead time to understand what’s changing, why, and how it affects their families. A communication timeline should begin 4–6 weeks before enrollment opens and include multiple touchpoints.

3. Personalized, One-on-One Benefits Education

This is the component most employers underinvest in, and the one that moves the needle most. SHRM’s research confirms that employees who receive one-on-one benefits counseling feel significantly more confident in their decisions. Confident employees choose better-fit plans, enroll in more voluntary benefits, and generate fewer post-enrollment questions for HR.

4. Year-Round Benefits Support, Not Just Open Enrollment Help

Employees encounter benefits questions throughout the year, when they get married, have a child, face a major health event, or onboard as a new hire. A benefits communication strategy that only activates during open enrollment leaves those moments unaddressed. Year-round support, whether through a call center, benefits counselor, or digital tool, keeps employees informed and confident.

Why Employee Benefits Communication Is a Broker Conversation, Not Just an HR One

Most brokers negotiate hard on rates, build solid plan designs, and then hand off. The communication and employee education piece gets treated as the employer’s problem to figure out.

The result is predictable: clients invest in strong benefits packages, employees don’t understand or use them well, HR gets overwhelmed every January, and no one is particularly satisfied at renewal time.

Brokers who take ownership of the communication piece change that equation. When you bring a full benefits communication and enrollment support solution to the table alongside rate negotiations, you stop being the person who delivers quotes and start being the partner who delivers outcomes.

That’s a harder relationship for a client to walk away from.

Brokers who solve the communication problem don’t just retain clients longer — they differentiate from every other broker competing on price alone.

The Bottom Line on Employee Benefits Comms

Employee benefits communication is not a soft-skills issue. It is the difference between a benefits strategy that produces results — engaged, loyal, productive employees — and one that simply costs money.

If your clients are spending on benefits and still hearing frustration from employees, or if HR teams are still drowning in post-enrollment questions every January, the plan design is probably fine. The communication is not.

That’s a solvable problem. And brokers who solve it become the most indispensable person in the room.

Let’s talk about what that looks like for your clients.

Want to talk through the employee benefits communication plan you want to pitch your client? Reach out, and we’ll make a plan together.

— Andy

Blog Title Card with Cleveland skyline, says Notes from Andy: Why ICHRA isn't just for small businesses

Why ICHRA Isn’t Just for Small Businesses

By Blog, ICHRA No Comments

By Andy Stein, Founder & President, The Worksite Group

Let’s Clear Up One of the Biggest Misconceptions in Benefits: ICHRA isn’t just for small businesses

You’ve probably heard this in one of your client conversations: “Isn’t ICHRA just for small businesses that can’t afford real group health insurance?”

It’s an outdated idea that’s costing employers—especially mid-sized and larger ones—opportunities to solve real problems.

Here’s what’s actually happening.

The Data Doesn’t Lie

ICHRA adoption among large employers jumped 34% from 2024 to 2025. Not small businesses. Large employers.

When trends like these start popping up, we can bet that the market rationale is driving adoption. Strategic-thinking CFOs and benefits leaders have done the math and realized traditional group health isn’t the only game in town anymore.

Why Large Employers Are Making the Switch to ICHRA

Getting Off the Renewal Rollercoaster

This great article from Peterson-KFF quotes a Chief Medical Officer who was experiencing 25-30% renewals. Then year three? A 47% increase. Asking for relief from the traditional carrier didn’t help; because of chronic illnesses within the employee pool, the carrier told the team that they’re still “shouldering losses” on behalf of the employer.

We’ve heard similar stories from brokers talking to clients who need help. That kind of budget hit is just not sustainable. 

When you’ve got 100, 200, or 500 employees, one or two people with serious ongoing medical conditions can seriously affect your options. The carrier underwrites your client’s specific group, and suddenly, they’re staring at increases that make them question whether they can even stay in business.

ICHRA flips that script. The employer sets the contribution. The employees buy individual market plans that don’t vary based on anyone’s health status—just age, and even that’s capped at a 1:3 ratio. You can get your client out of the business of unreasonably high renewals when someone on their team gets sick.

Having this cushion protects both the business and the broader employee base from unsustainable cost spikes.

ICHRA Compliance That Actually Works

If you’re employing over 50 full-time employees, you’ve still got ACA requirements. ICHRAs meet them, as long as your contribution makes coverage affordable—meaning the employee’s cost for the lowest-cost Silver plan doesn’t exceed 9.02% of their income in 2025.

This isn’t some sketchy workaround. It’s a legitimate compliance strategy that’s been around since 2020 and is only getting stronger policy support. The 2025 CHOICE Arrangement Act is working to make ICHRAs permanent. States are introducing incentive frameworks. This isn’t going away.

Solving the Complicated Workforce Problem

Your clients have remote employees in eight states. Or seasonal workers. Or they’re acquiring new entities every quarter and trying to bolt them onto existing benefits structure.

Traditional group plans weren’t built for that. Carriers limit their footprints. Minimum participation requirements make it hard to include part-timers. Adding a new entity takes months of setup.

ICHRAs let you create classes—full-time, part-time, salaried, hourly, different locations—and set appropriate contributions for each. That’s the difference between benefits that scale with your business and benefits that hold you back.

“But What About the Downsides to ICHRA?”

Look, I’m not going to pretend ICHRAs are perfect for everyone. They’re not. Here are a few legitimate reasons why your client may need a different choice.

Network Concerns Are Real

Most individual market plans are HMOs or EPOs—no out-of-network coverage outside emergencies. If your employees are used to PPOs with broader networks, that’s an adjustment.

But here’s what’s changing: Insurers focused on the ICHRA market are starting to offer off-exchange individual plans with PPO networks that look more like traditional group coverage. It’s not available everywhere yet, but the market is responding.

You need to look at what’s available in your specific area. If the networks mimic your client’s benefit offerings, it could be a good fit. If they don’t, an ICHRA might not be the right move right now. It may hurt your credibility to pretend otherwise.

Employees Need Support

Can your employees navigate dozens of plan options and make good decisions?

Honestly? Not without help.

That’s why the ICHRA vendors who know what they’re doing provide real support—decision tools, cost calculators, and licensed benefits counselors who actually walk employees through the options. This isn’t dropping a website link and wishing them luck.

This is why we provide so much wrap-around support when we help brokers through ICHRA transitions. Satisfaction is directly tied to employees’ ability to find the coverage they need within their allowance. Our experts partner with them in this search on your behalf, drastically increasing the likelihood of success.

When done right, employers are seeing up to 95% satisfaction after their ICHRA transitions.

This Isn’t 2020 Anymore

When ICHRAs first became available, the infrastructure was rough. Vendors were figuring things out. Employers were pioneers.

Five years later? The market’s matured. You’ve got vendors with sophisticated platforms that integrate with payroll, automate compliance reporting, pay insurers directly, and provide support that rivals traditional group plan experiences.

Large employers aren’t being asked to be guinea pigs. They’re adopting proven solutions with established support systems.

The Bottom Line

ICHRAs aren’t just for small businesses. They’re for any employer ready to think about health benefits differently.

Does that mean they’re right for your client? You’re the expert here. It will depend on their specific workforce, market, and timeline. 

But don’t write them off because someone told you they’re “only for small companies.” That ship sailed about 500,000 enrolled lives ago.

 

Still not sure if ICHRA is the right move for your client? Reach out, and we’ll find the real answer together.

— Andy

What We Learned from 250+ ICHRA Implementations (And What It Means for Your 2026 Strategy)

By Blog, ICHRA No Comments

By Andy Stein, Founder & President, The Worksite Group

We just closed the books on another year, and as I look back at the implementations we handled in 2025, a few patterns keep showing up. Some are encouraging. Some are frustrating because they’re completely preventable.

If you’re a broker or consultant reading this, you’ve probably had conversations with clients about ICHRA. Maybe you’ve closed a few deals. Maybe you’re still on the fence about whether it’s right for your book of business. Either way, the lessons we’ve learned from working with 250+ clients might save you some headaches in 2026.

The Biggest Mistake Brokers Made in 2025

Here it is: waiting too long to have the conversation.

I get it. Nobody wants to be the broker pushing the “new thing” when traditional group health has worked for decades. But here’s what happened over and over in Q4: Brokers would get a renewal in October showing a 35% increase, panic, and then call us asking if we could get an ICHRA implementation done by January 1st.

The honest answer? Sometimes yes, but it’s not pretty. And more importantly, it shouldn’t have come to that.

The brokers who had the best outcomes started the ICHRA conversation in August or September. Not because they had a crystal ball, but because they knew their clients were getting crushed and they needed options on the table before renewal panic set in.

The lesson for 2026: If you’ve got clients renewing in Q4, start the conversation now. Not in September. Now. In January.

What Actually Makes ICHRA Implementations Succeed

We’ve seen 250+ of these rollouts, and the successful ones have three things in common:

1. Proper Timeline (Not Rushed)

The November 15th deadline for a 1/1 effective date isn’t arbitrary. It’s the difference between a white-glove implementation and a scramble. When brokers give us 6-8 weeks, we can:

  • Do proper census review and cost modeling
  • Structure classes correctly for compliance
  • Build comprehensive employee communication strategies
  • Coordinate on-site counselors at major locations
  • Set up year-round support infrastructure

When we have two weeks? We can probably pull it off, but employees feel the difference. And guess who hears about it? You do.

2. The Human Element (Not Just Technology)

Every quarter, we compete against tech-only platforms that promise easy setup and low costs. And every quarter, we win business from brokers who tried those platforms and watched their client relationships suffer.

Here’s the reality: ICHRA isn’t just a technology problem. It’s a change management problem. Employees who’ve had traditional group health for 20 years don’t just need a platform. They need education, hand-holding, and someone to call when they’re confused at 7 PM during open enrollment.

That’s why our implementations include licensed benefit counselors, on-site support at major locations, and year-round call center access. Not because it’s a nice add-on, but because without it, ICHRA adoption falls apart.

The lesson: When evaluating ICHRA partners, ask what happens after the platform is configured. If the answer is “our customer service team,” you’re going to have problems.

3. Broker Relationship Protection (Not Bypass Attempts)

I need to be direct about something: Some ICHRA vendors see brokers as obstacles to remove, not partners to support. They’ll go around you the second they can. We’ve built our entire business on the opposite philosophy.

You own the client relationship. You should. You’ve earned it. Our job is to make you look like the innovative strategic advisor who brought them a solution that actually works, and then to deliver on that promise so well that the client never thinks about leaving you.

The lesson: Choose partners who understand that your success is their success. If a vendor is talking about “direct to employer” strategies, they’re not your partner.

The Short-Term Renewal Strategy Nobody Uses (But Should)

Here’s something most brokers don’t know: Carriers will often negotiate short-term renewals to keep the business.

Let’s say you’ve got a client who just got hammered with a brutal 1/1 renewal, and you’re reading this thinking, “Great insights, Andy, but it’s January 6th and we’re past the deadline.”

Not necessarily.

Call the carrier and negotiate a two-month short-term renewal. Worst case, they say no. Best case, you’ve just bought yourself runway to implement ICHRA properly for a 3/1 effective date instead of rushing a bad setup or accepting another year of crushing increases.

We’ve done this multiple times. It works more often than brokers think.

The “Test the Waters” Approach for Skeptical Clients

One strategy we saw gain traction in 2025: new hires only.

For clients who are nervous about moving their entire population to ICHRA, start with new hires while grandfathering existing employees. New hires don’t know what they’re missing, and within 6-12 months, you’ve got real performance data to show the CFO.

Results speak louder than projections. Let the ICHRA performance with new hires do the selling for you, then transition the rest of the population when everyone’s comfortable.

Beyond ICHRA: The Employee Navigator Opportunity

Here’s a possibility for ICHRA implementations that isn’t used enough in sales conversations: enveloping Employee Navigator and ICHRA into a single user interface for employee benefits.

Employee Navigator can streamline all of the benefits not covered by ICHRA, and we can integrate ICHRA into this package so that the client gets an all-in-one experience. 

We integrate these two systems into one client workflow, keeping things simple for the client; we manage both systems on your behalf, keeping things simple for you.

The lesson: Think of ICHRA as an opportunity to streamline the entire benefits portfolio, make life easier for your client, and put the entire benefits package under one vendor contract.

What 2026 Looks Like

If I had to make predictions based on what we’re seeing:

More mid-year implementations. Brokers are getting smarter about not waiting for 1/1 deadlines. April, July, and October effective dates are becoming more common.

More “test the waters” approaches. Risk-averse clients are finding comfort in phased rollouts starting with new hires.

More platform consolidation. Clients are tired of managing ICHRA on one platform and everything else on another. Unified solutions win.

More focus on the human element. As more tech-only vendors enter the space, the differentiation is in implementation quality and ongoing support.

The Bottom Line

After 250+ implementations, here’s what we know for sure: ICHRA works. But success isn’t about the technology. It’s about proper implementation, realistic timelines, employee education, and partnerships built on protecting broker relationships rather than bypassing them.

If you’re thinking about ICHRA for clients in 2026, start those conversations now. Not when you see the renewal. Not when the client is panicking. Now, in January, when you have time to do it right.

And if you’ve got questions about whether a specific client situation is a good fit, or whether the timeline works, let’s talk. That’s what the consultant for consultants is here for.

Ready to discuss your 2026 strategy? Contact us to talk through your client opportunities, or sign up for our monthly newsletter for ongoing insights from the benefits trenches.

Let’s connect—and raise the bar together.

Andy Stein
Founder, The Worksite Group