ICHRA enrollment tripled in 2025. Here’s the opportunity most GAs are still leaving on the table.
Published on May 07, 2026
By: Ideon
Carriers are all-in on ICHRA. Employers are asking about it. Brokers know they need to offer it. The GAs that make it easy are going to win the most loyal broker books in the market.
ICHRA enrollment tripled from 2024 to 2025. Among large employers — companies with 100 or more employees — ICHRA adoption grew 49% year over year. Among small employers, it was up 52%. Over the last five years, ICHRA participation has grown more than 1,000%.
This isn’t a trend to watch anymore. It’s a market shift to navigate.
The signal from carriers is equally clear. Oscar Health is exiting traditional small-group health insurance specifically to concentrate on ICHRA, calling it out in investor presentations as a primary growth driver for the next three years. Centene launched Ambetter Health Solutions — a dedicated ICHRA division — with off-exchange ICHRA plans now available in 13 states. Highmark is making similar moves. The carriers who know the individual market best are betting on ICHRA as the future of employer-sponsored coverage for the small and mid-market.
So the question for general agencies isn’t whether ICHRA is real. It is. The question is whether your GA is positioned to capture it — or whether you’re watching the opportunity flow to the brokers, platforms, and carriers that got there first.
Why most brokers aren't capturing their ICHRA opportunity
92.8% of brokers say they believe ICHRA adoption will increase significantly over the next five years. And yet two-thirds of brokers currently selling ICHRA have five or fewer clients.
The gap between expectation and execution is a tool problem, not a motivation problem.
Selling ICHRA to an employer group requires, at minimum: comparing ICHRA contribution amounts against individual market premiums by employee ZIP code; assessing network access at the employee level; modeling subsidy eligibility for employees who qualify; and benchmarking total employer cost against fully-insured and level-funded alternatives — all in one output the broker can actually show an employer.
On a standard fully-insured renewal, most of that work is automated. A broker submits a census, a quoting platform returns structured options, and the comparison is ready to present.
On an ICHRA evaluation today, almost none of it is automated at the GA level. Brokers pull individual market premiums from a separate platform. They model subsidy eligibility in spreadsheets. They reconcile the ICHRA output against a group quote that lives in a different system. They build the recommendation by hand — across multiple tools that don’t talk to each other.
Brokers know they should be offering ICHRA on qualifying renewals. But when the analysis takes most of an afternoon, they run it on the deals where someone explicitly asked. They skip it on the renewals where surfacing ICHRA proactively would require extra work. The opportunity goes uncaptured — not because it isn’t there, but because the tools to find it efficiently don’t exist in their GA workflow.
What a GA-level ICHRA capability actually looks like
The GAs that have successfully scaled broker ICHRA practices share specific capabilities that separate them from firms where ICHRA is still a special-request workflow.
Proactive ICHRA flagging on qualifying renewals
The most important shift isn’t the analysis itself — it’s when the analysis happens. GAs that win on ICHRA surface the opportunity at the start of a renewal, not after a broker asks.
The criteria for flagging are well-established: groups in high-adoption states (Texas, Florida, Georgia, North Carolina, Tennessee, Indiana, Arizona); employer sizes in the 10–200 life range where individual market premiums are most competitive; and groups with geographic dispersion across multiple ZIP codes where ICHRA’s flexibility is most valuable.
When ICHRA eligibility surfaces automatically as part of a renewal intake, running the comparison costs a broker a few minutes. When they have to decide whether to initiate the analysis manually, it costs an afternoon. Most skip it. Proactive flagging removes that decision — and changes how often ICHRA gets onto the employer’s table.
A unified comparison across funding models
The clearest gap in the GA broker tool market today is the absence of a single output that shows fully-insured, level-funded, and ICHRA side by side, with enough structure that a broker can walk an employer through it in a meeting.
Today, those three analyses live in three different systems. Brokers who want to present a complete picture build it manually — pulling data from a group quoting platform, a level-funded carrier portal, and a standalone ICHRA platform, then reconciling the numbers into a coherent comparison format.
GAs that eliminate that manual step give brokers a meaningful capability advantage on every deal where ICHRA or level-funded is relevant — which, in the current market, is nearly every group renewal.
Employee-level network analysis for ICHRA plans
The objection brokers hear most on ICHRA is about doctors: “My employees want to keep their current providers. Can they do that on an individual market plan?”
Answering this confidently requires individual market plan data at the ZIP level and provider network data for each plan option — so a broker can show, specifically, which ICHRA-eligible plans in that market preserve the group’s existing provider relationships and which don’t.
This is the piece that turns an ICHRA conversation from a concept into a recommendation. Without it, the broker presents contribution amounts and premium ranges. With it, the broker presents a specific plan recommendation, backed by network fit data, that an employer can act on.
The carrier investment signal is worth taking seriously
It’s one thing for an emerging benefit structure to grow on the demand side. It’s another when the largest carriers in the individual market reorganize around it.
Oscar Health’s decision to exit small-group insurance was explicit: the company sees ICHRA as a better long-term opportunity for its individual market expertise than competing in traditional group. Ambetter/Centene didn’t just add ICHRA plans — they built a dedicated organizational structure around ICHRA distribution, with plans available across Arizona, Florida, Georgia, Indiana, Kansas, Mississippi, Missouri, Nebraska, Ohio, Oklahoma, South Carolina, Tennessee, and Texas. Highmark is making similar strategic moves into the ICHRA market.
These are carriers that know individual market enrollment, provider network dynamics, and state-by-state plan design better than anyone. When they restructure business units around ICHRA, it’s a durable market signal — not a feature addition.
The practical implication for GAs: the ICHRA-specific plan data landscape is getting more complex, not less. Ambetter’s ICHRA plans have different designs and pricing from its standard ACA plans. Oscar’s ICHRA offerings are built around a distinct member experience model. Tracking and normalizing this data — across carriers, states, and plan years — is increasingly important for any GA that wants to surface ICHRA as a real option, not just an abstract alternative.
The employer retention data makes the opportunity concrete
One of the strongest signals in the ICHRA data is retention: 92% of employers who offered an HRA in one year continued to offer it the next. That’s a sticky benefit model.
Brokers who help an employer implement ICHRA own a long-term relationship — not just a renewal. The employer is counting on them to manage contribution strategy year over year, navigate carrier and plan changes each open enrollment period, and help employees make sense of their individual market options. That’s a fundamentally deeper advisory role than a group insurance renewal creates.
For GAs, this translates directly: the broker who closes an ICHRA deal with GA support is more dependent on that GA than a broker who closes a fully-insured renewal. The analysis, the ICHRA-specific carrier relationships, the network data — those capabilities live at the GA layer, and they make the broker relationship stickier in both directions.
What the data infrastructure challenge actually looks like
The capability gap isn’t about training brokers on ICHRA. Most brokers who’ve been exposed to it understand the mechanics. The gap is infrastructure — and it lives at the GA level.
Running a meaningful ICHRA comparison requires:
- Individual market plan and premium data at the ZIP level, structured by employee demographics and family composition
- Subsidy eligibility modeling by employee income band
- ICHRA-specific carrier plan data — including the dedicated plan designs from Ambetter, Oscar, and others built specifically for ICHRA distribution
- Provider network data for individual market plans, at the granularity required to compare against a group’s existing provider relationships
Most GAs don’t have this data in one place. They have group plan data in their quoting infrastructure and ICHRA data outside it — which means every ICHRA comparison requires a context switch, a manual reconciliation, and a slower recommendation cycle.
The GAs closing this gap are doing so through the data layer: normalizing individual market, level-funded, and group plan data into a single source so comparison can be automated. That architecture change is what separates GAs where ICHRA is a niche offering from GAs where it’s a standard part of every qualifying broker conversation.
Frequently asked questions
Q:What states have the highest ICHRA adoption in 2026?
ICHRA adoption is highest in states where individual market premiums are most competitive relative to group rates: Texas, Florida, Georgia, North Carolina, Tennessee, Indiana, and Arizona are the top markets. These are also the states where Ambetter, Oscar, and other carriers have concentrated their ICHRA-specific plan investments.
Q:Why are most brokers still stuck at five ICHRA clients?
The primary constraint is workflow friction. ICHRA analysis today requires multiple tools and manual reconciliation across systems that don’t connect. Brokers run it on deals where someone explicitly asks. GAs that integrate ICHRA comparison natively into the broker workflow remove that friction — and change how often ICHRA gets onto the employer’s table.
Q:What’s the difference between ICHRA and level-funded insurance?
ICHRA is an employer-funded benefit where employers provide employees a fixed monthly allowance to purchase individual market health insurance. Level-funded is a small group arrangement structured like self-insurance but with predictable monthly costs and stop-loss coverage. They serve different employer profiles and aren’t interchangeable — a complete GA broker tool surfaces both alongside fully-insured options in a unified comparison.
Q:Why are carriers like Oscar and Ambetter restructuring around ICHRA?
Both carriers have individual market expertise that translates well to ICHRA — strong state-level plan design, enrollment infrastructure, and provider networks suited to individual market members. ICHRA brings employer volume to the individual market without the rating restrictions and participation requirements of group insurance. For carriers positioned in the individual market, it’s a natural growth path.
Q:How can a GA surface ICHRA proactively on every qualifying renewal?
Proactive ICHRA flagging requires structured eligibility criteria — employer size, state, current premium benchmark — combined with individual market data that makes a quick comparison available before a broker initiates the analysis manually. GAs with API-based individual market data can build this flag into their intake workflow so it surfaces automatically on qualifying groups.
What Ideon provides
Ideon is the data infrastructure that powers ICHRA comparison, network disruption analysis, and cross-funding-model tools for GAs and benefits platforms.
Ideon’s data layer covers individual market plan and rate data across all 50 states; structured ICHRA-specific carrier data including dedicated ICHRA plan offerings from Ambetter, Oscar, and others; level-funded product data; and provider network data for 300+ carriers and 8.5M providers.
GAs building ICHRA comparison and cross-funding-model capabilities on Ideon’s API launch in 6–12 weeks rather than 12–18 months. The data infrastructure is already built, maintained across 50 states, and updated as carrier ICHRA plans evolve each plan year.
If ICHRA is a capability you’re trying to move from “we do this on request” to “we do this on every qualifying deal,” a walkthrough of Ideon’s data and API is the right starting point.