By Andy Stein, Founder & President, The Worksite Group
Last updated June 2026
A lot of brokers aren’t avoiding ICHRA conversations because they don’t believe in the model. They’re avoiding them because they don’t have a clean answer to the PPO question.
A client asks: “What about my employees’ doctors? Will they still be in-network?” The broker hasn’t done the state-by-state market research to answer that confidently, so the conversation stalls there. ICHRA stays off the table, and the client ends up absorbing another year of group plan increases that ICHRA administration might have solved.
When I was at the 2026 ICHRA Conference in Nashville, Alan Silver, President of ICHRA at Ambetter Health (Centene), addressed this directly. His point: not every employee actually needs a PPO. He went on to say that at Ambetter, they tracked the use of their PPOs, and over 90% of the members stayed in-network. That’s not a dismissal of the concern. It’s an invitation to get more precise about what “network access” actually means for a specific employee population in a specific market.
That precision is the broker’s job. Here’s how I think about it.
Why do most individual market plans use HMOs and EPOs instead of PPOs?
Most individual market plans are HMOs or EPOs because closed networks allow carriers to negotiate tighter provider contracts, which keeps premiums lower. PPOs, which allow out-of-network access, are more common in the group market where large employer purchasing power makes broader networks financially viable. According to Peterson-KFF (October 2025), limited PPO availability in the individual market is among the most frequently cited barriers to ICHRA adoption.
That’s the structure you’re working with, and it’s not going to change overnight. The question is whether it’s actually a problem for your specific client’s workforce, or whether the need for a PPO is an assumption that hasn’t been tested.
Individual market plans can carry meaningfully lower premiums than comparable group coverage, particularly in states where the individual market is more competitive. The KFF 2025 Employer Health Benefits Survey found average family premiums hit $26,993 in 2025, up 6% year over year. That’s the third consecutive year of 6%+ increases. Employers are paying more every year for coverage that may or may not match what their employees would choose if given a choice. That context matters when you’re evaluating whether a narrower network is a deal-breaker.
Does ICHRA give employees equal access to the health networks they’re already using?
It depends entirely on the state. ICHRA is a state-by-state product design. The right question is not whether ICHRA offers a PPO, but whether the HMO and EPO options available in that state cover the hospitals and specialists your employees are already using. If they do, the plan type is largely irrelevant to access. If they don’t, ICHRA is probably not the right answer for that group right now. See the Peterson-KFF analysis for employer-reported network outcomes.
This is the framing I keep coming back to: the goal of network access isn’t a particular plan type. It’s equal access to the providers employees are already counting on. An HMO that includes your market’s major health system achieves that. A PPO that doesn’t actually include those providers doesn’t.
The Peterson-KFF analysis surfaced this directly from employers who made the move. One CFO noted that employees could now choose which health system they wanted to be in rather than being placed into one. Another said employees were getting at least the same level of coverage as the old group plan, with more flexibility to find the doctors they wanted to see. Those results don’t come from PPO access. They come from a market where the available networks matched what employees actually needed.
Where that match doesn’t exist, the outcome is different. The same KFF data showed one employer’s satisfaction rate drop from 95% to 89% in year two, not because ICHRA failed, but because employees in that market didn’t have enough support to navigate the options available to them. A market where the networks don’t reflect employee needs makes that problem significantly worse. Recommending ICHRA there would be the wrong call, and I think most brokers sense that, which is why they hesitate.
But I encourage brokers to do the research so that the hesitation is gone next time they have the ICHRA conversation. If it’s the right solution, this could really save your client money without disrupting their employees’ care, earning you a loyal client.
What does ICHRA administration look like on a state-by-state basis, and why does it matter?
ICHRA plan availability, carrier offerings, network coverage, and premium levels all vary significantly by state and sometimes by county. A broker advising clients in multiple states is working across multiple distinct individual insurance markets. Strong ICHRA administration includes this state-level market analysis as a baseline, so brokers can evaluate fit accurately before recommending the model. Without that groundwork, the PPO objection has no good answer.
This is where the broker’s homework gets specific. For each market you serve, you need to know: which carriers are active in the ICHRA space, both on and off exchange; what the network footprints look like relative to the major health systems in that area; and whether the premium levels make the economics work for your client’s contribution strategy.
Some carriers have been building specifically for this. Ambetter Health, through Centene’s ICHRA division led by Alan Silver, has been developing off-exchange individual market products designed to address employer and employee concerns about network access. Oscar Health has built a dedicated ICHRA division with similar intent. The market is responding to the PPO gap. But it’s not responding uniformly, and the pace of that response varies by state.
A broker in Indiana, Ohio, or Kentucky is working three different individual markets. What’s available off-exchange in one state may not exist in another. That research can’t be skipped and it can’t be generalized. It’s the work that earns you the right to have a confident ICHRA conversation with a client.
This is also where a strong ICHRA administration partner adds real value. Part of what we do at TWG is take this state-by-state analysis seriously so brokers aren’t starting from zero. If you’re evaluating whether ICHRA fits a client’s market, we can help you look at what’s actually available before you walk into that room.
How fast is ICHRA adoption growing, and what does the data say about employer satisfaction?
ICHRA adoption has grown more than 1,000% since 2020, with total enrollment between 500,000 and 1 million people according to the HRA Council’s 2024–2025 Growth Trends report. Large employer adoption grew 34% year over year. More than 9 out of 10 employers who offered an ICHRA in a prior year renewed it for 2025, which is the strongest indicator available that the model is working in the markets where it’s being deployed.
That retention number matters. Employers aren’t trying ICHRA and walking away. They’re staying with it. And the 83% of new adopters who had never previously offered health coverage at all, per the HRA Council data, aren’t bringing PPO expectations into the comparison, which makes the access question more straightforward.
For the 17% who transitioned from traditional group plans, many were dealing with renewals that made group coverage unsustainable. The KFF research documents employers facing 25–30% increases, then 47% in year three. When the alternative is a structured individual market where employees can access the same major health systems through an HMO at a significantly lower premium, the plan type difference becomes secondary.
The growth in large employer adoption, from a 44% increase in the 50–99 employee segment to 49% growth in the 100–199 segment per the HRA Council data, tells you this isn’t just small businesses in easy markets anymore. Strategic benefits teams are doing this analysis and finding that it works. That’s worth knowing when you’re calibrating how seriously to take the PPO objection.
How should brokers address the PPO question with clients who raise it?
Don’t sidestep it. Engage it with a state-specific answer: the individual market in most states uses HMOs and EPOs rather than PPOs, and whether that’s a problem depends on whether the available networks in your state cover the providers your employees are already using. That evaluation is the broker’s job to do before walking into the recommendation, not after the client raises the concern.
“The individual market in most states offers HMO and EPO plans rather than PPOs. What that actually means for your employees depends on what’s available in your market. Before we make any recommendation, we’re going to look at whether the networks your employees are already using are covered by the ICHRA options in your state. If they are, we keep the conversation going. If they’re not, we tell you that clearly.”
That’s a credible answer. It doesn’t oversell the model. It puts the analytical work where it belongs, on you, before you make a recommendation. And it’s the kind of specificity that distinguishes brokers who are building real ICHRA capability from those who are just deferring the conversation.
The brokers who are winning ICHRA business aren’t the ones who avoid the hard questions. They’re the ones who show up to those conversations having already done the market research to answer them.
If you’re evaluating ICHRA fit for a specific client and want to work through what the individual market looks like in their state, reach out. That’s exactly the kind of conversation we have with brokers every day.
Frequently Asked Questions
Does ICHRA allow employees to choose a PPO plan?
It depends on the state. ICHRA gives employees access to any ACA-compliant individual market plan, including PPOs where they’re available. PPO options in the individual market are limited in many states, where most plans are HMOs or EPOs. Some carriers, including Ambetter Health through Centene’s ICHRA division, have been developing off-exchange products with broader network designs specifically for ICHRA-funded employees. The right starting point is understanding what’s available in your client’s specific market before drawing any conclusions.
What is ICHRA administration, and what does a qualified ICHRA administrator actually do?
ICHRA administration covers the full operational layer of running an individual coverage HRA: designing the plan structure, establishing employee classes, setting contribution amounts, verifying that employees are enrolled in qualifying coverage, and processing reimbursements. It also includes the employee-facing support that matters most at enrollment, which is decision tools and licensed benefits counselors who help employees select a plan that fits their situation and their market. The quality of that enrollment support directly affects employee satisfaction. According to Peterson-KFF’s 2025 analysis, employers whose employees received adequate plan selection support reported meaningfully higher satisfaction than those who didn’t. Choosing the right ICHRA administrator matters as much as the product itself.
If the individual market in a state doesn’t have strong networks, is ICHRA the wrong answer?
Possibly, and it’s worth saying that directly rather than pushing through. If the HMO and EPO options available in that state don’t cover the health systems and providers employees are already using, ICHRA isn’t giving those employees equal access to their care. That’s a real limitation, and the honest answer is to say so. In those markets, the better move might be to revisit the conversation as the carrier landscape develops, or to evaluate whether ICHRA makes sense for a specific employee class rather than the full group.
How does ICHRA compare to traditional group health insurance for employers with 50 to 200 employees?
For employers in that range, the comparison comes down to cost predictability, workforce complexity, and what the individual market looks like in their geography. Large employer ICHRA adoption grew 34% year over year in 2024–2025 according to the HRA Council, with the 100–199 employee segment growing 49%, the fastest of any cohort. Those employers are typically choosing ICHRA because it removes health status risk from their renewal equation, allows different contribution levels for different employee classes, and in states with competitive individual markets, delivers comparable or better coverage at lower total cost. It’s not the right answer for every employer in that range, but it’s a serious option that belongs in the evaluation.
Can brokers still earn commissions when a client moves to ICHRA?
Yes, though how commissions work varies by ICHRA administrator. Individual market plans carry commissions, and some administrators structure arrangements so the originating broker remains the broker of record and retains that income. Others take on that role themselves at renewal. It’s an important question to ask upfront when evaluating administration partners. At TWG, we work as a back-office administration partner, not a broker replacement. We’re built to support the broker relationship, not displace it.
What should brokers look for when evaluating ICHRA vendors and administrators?
Four things matter most. First, do they have real visibility into off-exchange plan options in the states you serve, not just on-exchange marketplace plans? Second, do they provide licensed benefits counselors who work directly with employees at enrollment, or just a platform login? Third, how do they handle commission arrangements for the originating broker? And fourth, what does their reimbursement verification and compliance infrastructure look like? The KFF research is clear that the quality of employee-facing enrollment support is the primary driver of satisfaction outcomes. An ICHRA administrator that hands over a platform and disappears creates a very different result than one that stays engaged through the full enrollment cycle.
What is the difference between on-exchange and off-exchange ICHRA plans?
On-exchange plans are purchased through the ACA marketplace and are eligible for premium tax credits. Off-exchange plans are purchased directly from carriers and are not eligible for those subsidies. Most employees using employer ICHRA funds purchase off-exchange, since the IRS rules governing ICHRA affordability generally make premium tax credits unavailable to employees who accept an affordable ICHRA offer. Off-exchange plans often include carrier-developed options with broader networks than what’s available on the marketplace, which is why understanding what carriers offer off-exchange in a given state is an important part of the ICHRA market evaluation.
Sources
Peterson-KFF Health System Tracker: “Explaining Individual Coverage Health Reimbursement Arrangements (ICHRAs),” October 2025 — healthsystemtracker.org
HRA Council: Growth Trends for ICHRA & QSEHRA, Volume 4, 2024–2025 — hracouncil.org
KFF 2025 Employer Health Benefits Survey — kff.org/health-costs/2025-employer-health-benefits-survey
ICHRA Conference 2026, Nashville, TN, May 13–14, 2026 — ichraconference.com
Alan Silver, President of ICHRA, Ambetter Health / Centene — ambetterhealth.com/en/employers
Ready to talk through ICHRA opportunities for your book of business? Let’s connect.
— Andy Stein, Founder & President, The Worksite Group
