Top Takeaways for Brokers & Administrators:
- Issues like poor education, misalignment, and rushed timelines happen repeatedly and can be solved with better planning.
- Brokers are moving from plan placement to full ecosystem coordination, including vendor selection and employee experience.
- If HR is not educated and bought in early, confusion spreads quickly and undermines the rollout.
- Payment friction, service inconsistency, and lack of ICHRA familiarity can disrupt the experience if not managed carefully.
There was one session at the HRA Council Foresight Forum that stuck more than the others, and it had nothing to do with market projections or where ICHRA might be five years from now. It focused on what happens when a broker sits down with an employer and tries to make this work in the real world.
If I had to sum it up simply, ICHRA is not struggling because people do not believe in it. It is struggling in places because we are not implementing it consistently yet.
We are not dealing with an awareness problem anymore. Most people understand what ICHRA is and why it matters. The gap is in how consistently it is being executed.
“Brokers are hired to think and to know the things the client doesn’t know they don’t know.” — Michael Uretsky, Gallagher Benefit Services
That responsibility feels a lot bigger in an ICHRA model. The broker is no longer just bringing plan options to the table. They are helping coordinate a system that includes carriers, administrators, HR teams, payroll, compliance, and a workforce that may be entering the Individual market for the first time.
Common ICHRA Implementation Challenges Are Predictable and Preventable
What surprised me is that the challenges being discussed were not new or surprising. They were patterns that tend to show up in the same way each time. Conversations start too late, timelines get compressed, education is treated as something that can be layered in at the end, and HR is not always fully aligned before rollout.
“They’re all avoidable, if you anticipate and have a process in place to address them.” — Michael Uretsky, Gallagher Benefit Services
Why Timing and Planning Make or Break ICHRA Rollouts
The conversation around timing was probably the most honest part of the session. Cassandra Roguchi pointed out that the worst implementations are not the most complex ones, they are the ones that start too late and try to make up for it during enrollment.
“The worst implementations are the ones that run on a runway and have almost no implementation time.” — Cassandra Rogucci, Gallagher Benefit Services
Once that happens, the first thing that gets ignored is education, and that has a ripple effect across everything else. Employees go into enrollment without enough context, questions spike, and HR ends up carrying more of the load than expected. What should feel structured starts to feel reactive. Trying to condense all of that into a short window, especially for a population that may be new to the Individual market, is where a lot of the friction begins.
There is still a tendency to assume that if you give people options, they will figure it out. In reality, choice without guidance creates hesitation. The challenge is not just explaining what ICHRA is, but making it understandable for different types of employees, at different levels of familiarity, in a way that actually helps them make a decision. “How do you simplify it so everybody can understand it on their level?” asked Cassandra.
If that part is not addressed, everything else becomes heavier. Enrollment takes longer, support requests increase, and what should feel like flexibility starts to feel like complexity.
Every ICHRA plan that gets forced down an HR partner’s throat is more painful than it should be. Employees go to HR first when they are confused, so if HR is not confident in how the model works, that uncertainty spreads quickly.
How the Broker Role Is Evolving in an ICHRA Model
There is still this idea that ICHRA reduces the role of the broker. What came through in this session is that the opposite is happening.
The broker is becoming the one responsible for making the system work. That includes setting expectations early, aligning stakeholders before rollout, and making sure the right partners are in place to support both the employer and employee experience. It is a more involved role, but also a more valuable one.
At one point, ICHRA was described as a group effort where everyone has a role to play.
“ICHRA is a team sport. It requires everybody on the team to do their job so that ultimately everybody wins.” — Michael Uretsky, Gallagher Benefit Services
Even with the momentum behind ICHRA, the ecosystem is not fully built out yet. There was a lot of candid discussion around the friction that still exists, especially with carriers. Some of it comes down to operational gaps, whether that is payment processes, service models, or simply a lack of familiarity with how ICHRA works in practice.
“Education gaps are winning by a mile,” shared Joe Caldwell from Evensun Health.
That applies across the board. Employees, HR teams, brokers, and carriers are all still catching up in different ways. And when those gaps show up, brokers are usually the ones dealing with the impact.
What Needs to Happen Next for ICHRA to Scale Successfully
Stepping back from the session, the takeaway for me is that ICHRA is not struggling because people do not believe in it. It is struggling because the execution is not consistent.
The fundamentals are there. The demand is there. But the next phase of growth is going to depend on whether this can be done in a way that is repeatable and easier to manage over time. That means starting earlier, investing more in education, bringing HR in sooner and more intentionally, and building processes that hold up beyond one enrollment cycle.
If that starts to come together, the conversation shifts. Not from “what is ICHRA” to “does it work,” but from “can we do this” to “how well can we do this.”
If you are a broker or administrator trying to build a more repeatable ICHRA approach, this is exactly the kind of problem the W3LL team is focused on. From education and enrollment support to the workflows that hold everything together, we are always open to talking through what is working and where things tend to break.
