Takeaways from HRA Council’s Foresight Forum:
- Real-world examples – a 3,500-employee multi-state workforce, shows that ICHRA is being used to solve complexity at scale.
- Employees are expected to choose plans, but confidence does not match reality. Without structured guidance and re-engagement, choice becomes friction instead of empowerment.
- Successful transitions require HR teams to actively guide employees, not just facilitate enrollment. When HR and employees are aligned and supported, adoption and satisfaction increase.
- The opportunity is not just in selling ICHRA, but in building a repeatable process that includes ecosystem coordination, year-two re-engagement, and ongoing education.
I got the chance to attend the first-ever HRA Council Foresight Forum, and I will say this right away, I was not expecting the level of focus this group brought to ICHRA. It is not often you get that many people in one place who are all working on different parts of the same problem, and you could feel that energy.
What stood out most to me was the range of perspectives. You had HR leaders, brokers, health plans, administrators, and technology partners all talking through how this works in practice, not just in theory. That part mattered because ICHRA is not one thing; it’s a system that only works if all of those groups are aligned.
The most consistent feedback I heard over the couple of days was not about policy or product gaps, it was about who was missing. People kept saying they wanted more employers, HR teams, and members in the room. That stuck with me because it says a lot about where we are as a market. ICHRA is growing, the ecosystem is forming, but the people we are ultimately building this for are still not fully part of the conversation yet.
At the same time, there was a clear sense that this is not about replacing anything that already works. If the small group market works for a business, no one is trying to take that away. The goal is to build something alongside it that gives employers another option that can scale in ways traditional models sometimes cannot.
I will share a few takeaways from the event, but the first one was hard to miss.
ICHRA Is Not Just a Small Employer Story
There is still thought that ICHRA is mostly for small groups, or that it is a stepping stone for employers who cannot sustain traditional coverage. That is not what I saw or heard at this event.
Some of the strongest examples came from large employers, those with 1,000+ employees across multiple states and job types. That kind of complexity is exactly where traditional group coverage starts to strain, and where a defined contribution model becomes a lot more practical.
HRASimple’s largest ICHRA-covered employer has over 5,000 lives. That is scale and market demand. What also came up in these conversations was how ICHRA can open the door for employees who were not enrolling in group coverage before, especially hourly workers. In those cases, this is not about shifting people from one plan to another. It is about giving them access to coverage options that fit their situation and they elect to adopt.
Data shared by Adam Pine from SureCo got people talking. He cited that 86% of ICHRA-funded members changed plans year-over-year, but 72% stayed with the same carrier. The way I took that is that year one is often about getting something in place, and year two is where people start to make more informed decisions once they understand how the individual market works.
That creates a clear opportunity for brokers to come back into the conversation after that first year and help people reassess their options. Not as a one-time enrollment event, but as something that should be built into the process.
There is still a real gap between having access to options and understanding what you are choosing.
“We discount the need for support and education.” – Michael Levin from HealthSherpa
That line stuck because it gets at the core challenge. If ICHRA is going to continue to scale, especially into larger employers, we cannot assume that access alone is enough. People still need guidance, context, and support to make the right decisions.
The Story Behind the HR Team That Transitioned 3,500+ Employees to ICHRA
One of the most practical examples shared at the forum came from Robin Hamel, who walked through how Carenet Health transitioned a 3,500-person workforce to ICHRA.
This is not a simple employer profile. They operate across 46 states with a large call center population, which brings a wide range of income levels, plan needs, and usage patterns. That kind of workforce is exactly where traditional group coverage can start to feel rigid, and where ICHRA starts to make more sense.
One of the biggest shifts she talked about was the role of HR. Instead of acting as the middleman between the employee and a single plan offering, HR became responsible for helping employees understand their options. Not the broker, but the educator. That mindset shift showed up in how they approached the rollout.
They set the same ICHRA contribution across the board, from the C-suite to the call center. That consistency matters because it reinforces the idea that everyone is getting access to the same system, even if they are making different choices within it.
And employees responded to that. Carenet saw a 20% increase in employees opting into the ICHRA offering compared to their traditional group plan. As Robin put it, “my broker brought ICHRA to me,” but what stood out more was how they executed on it internally. “We wanted people to be informed consumers.”
That intention shows up in the results, but it also ties directly to the makeup of their workforce. The population is over 80% female and skews younger, which naturally aligns with the individual market where premiums can be more affordable for that demographic. In that context, ICHRA is not just a structural change, it is a better match for how employees actually use healthcare.
In a separate conversation, Trevis Parson stated “overinsurance is chronic.” It is a simple way of describing something we all see. Employees often end up in plans that do not reflect how they use care.
ICHRA creates space for that to change. It gives employees, especially younger ones, the ability to shift down a tier and choose a plan that aligns with their usage instead of defaulting into something more expensive.
It also forces a different kind of engagement from employers. For a long time, the traditional group model has not required much active involvement beyond renewal season. Employers have not had to pay close attention, decisions have often been reduced to cost comparisons, large carriers have dominated the landscape, and employees have had limited meaningful choice. ICHRA challenges that model.
What It Takes for Brokers to Lead in an ICHRA Market
“The future of ICHRA depends on brokers.” – Peter Nelson, CMS-CCIIO
That is not an overstatement. If anything, it sets the expectation for how much the role is changing.
ICHRA is pushing brokers out of a traditional distribution mindset and into something closer to a consultant and ecosystem coordinator. This is no longer just about placing a plan. It is about evaluating vendors, guiding employers through change, and making sure the entire model works once it is live. There are a few challenges that kept coming up in those conversations.
- Compensation
The commission structure is not always as straightforward as it is in the group market, and that creates hesitation. Brokers have to think differently about how they are compensated across carriers, administrators, and services. The opportunity is still there, but it requires a shift in how value is defined and communicated to clients.
- Vendor Ecosystem
ICHRA does not work with a single partner. It requires coordination between administrators, enrollment platforms, carriers, and often payroll or HR systems. Brokers are now responsible for evaluating and stitching together that ecosystem.
- Market Readiness
Not every employer is ready for ICHRA, and not every workforce will respond the same way. Brokers need to be able to assess readiness honestly, which means looking at workforce demographics, geography, and appetite for change. It also means being comfortable guiding employers through something that may feel unfamiliar at first.
There was a strong message around how brokers show up in these conversations. Doug Moore from Seubert & Associates said it directly, “as a broker it does not matter if you think it is a good idea or not.” The point being that this is not about personal preference. It is about helping employers evaluate what is best for their organization.
That also means not trying to sell around HR. Brokers need to be true partners in this process, bringing together HR, leadership, and other stakeholders and making sure everyone understands what is changing and why. And when it works, it tends to stick.
“99% of the clients that moved to ICHRA have stayed with ICHRA.” – Michelle A Jukoski, HUB International
That kind of retention does not happen by accident. It comes from getting the structure right and supporting it over time.
There will be challenges. Most of them will come down to education. If employees do not understand their options, if employers are not fully bought in, or if the ecosystem is not set up to support them, things break down quickly.
That is why one of the more practical takeaways I heard was to expand your ecosystem deliberately. Work with partners who can check all the boxes. Doug called out administrators in particular, saying that having one that provides a high degree of enrollment support and works well with carriers was a must.
It is going to take employers who are willing to engage, brokers who are ready to lead, and a broader ecosystem that can actually support people through these decisions in a meaningful way. If we get that right, the impact goes beyond just another coverage model.
Final Thought
I’ll end with on last quote that really reflects where I see the market going over the next 5 years.
“We hope ICHRA will bring competition in the insurance market that we have never really had before.” – Peter Nelson, CMS-CCIIO
If you are a broker or administrator starting to explore ICHRA more seriously, this is the time to lean in. The W3LL team is ready to talk through strategy, share what we are seeing across the market, and help you build an approach that works in practice.
