June 2026 | By Softheon
Key takeaways for health plans:
- Health plans may already have ICHRA (Individual Coverage Health Reimbursement Arrangement) members without realizing it
- Billing, payments, and administrator coordination remain major operational gaps
- Members moving from group coverage expect a different experience than traditional Individual enrollment
- Broker and ICHRA administrator relationships are becoming critical distribution channels
During the kickoff session of Softheon’s ACAP (Association of Community Affiliated Health Plans) ICHRA learning series, Chief Growth Officer Kevin Deutsch led a discussion on the growing role of ICHRA in the Individual market and why health plans need to think beyond traditional Marketplace operations. The conversation covered everything from employer adoption trends and operational complexity to broker relationships, payment workflows, and the growing importance of multi-market member management.
While ICHRA is too often discussed as an emerging opportunity, Kevin challenges you to think about it differently. “Everybody is in ICHRA right now. If you don’t think you’re in ICHRA, you’re in ICHRA.”
Many health plans already have ICHRA members enrolling through their individual products today. The bigger question is whether plans are operationally prepared to recognize and support them differently.
ICHRA Is Becoming Part of the Individual Market Success Plan
Market pressures are pushing employers to reconsider traditional group coverage. Kevin pointed to rising small group premiums, state-level tax incentives, and growing unsubsidized Marketplace enrollment as factors increasing interest in ICHRA.
He highlighted a segment of the Marketplace population that often gets overlooked in ICHRA conversations. “There’s members that are enrolled On-Exchange today that are receiving no subsidy whatsoever.”
These individuals represent an opportunity for employers to contribute toward coverage through an ICHRA model rather than leaving employees to manage fully unsubsidized Individual coverage on their own.
ICHRA is not necessarily replacing traditional employer-sponsored insurance overnight. Instead, it is becoming another strategy employers are evaluating as costs continue to rise and workforce needs become more diverse.
Why ICHRA Members Expect a Different Billing and Payment Experience
Many employees entering ICHRA are not coming from traditional Individual market experiences. They come from employer-sponsored coverage, which changes how they expect billing, payments, and support to work. “These individuals who are now moving into ICHRA expect a similar type experience.”
He noted that many plans are unintentionally treating ICHRA members like standard Individual market members by sending invoices directly to members, requiring monthly payment management, and relying on workflows built for direct-to-consumer enrollment. This is one of the biggest operational gaps in ICHRA today.
“They wanna have the choice over the health insurance, but they don’t want anything to do, nor should they have anything to do with the billing and payment aspect.” – Kevin Deutsch
Supporting ICHRA successfully requires more than simply offering plans on the individual market. It requires operational models designed around how these members actually interact with coverage.
The Biggest Operational Challenges in the ICHRA Ecosystem
As ICHRA adoption grows, so does the number of organizations involved in the enrollment and administration process.
Kevin described the ecosystem as increasingly crowded and difficult for health plans to navigate. “There is a new ICHRA administrator popping up every single day.”
Audience members shared operational challenges associated with administrator coordination, enrollment workflows, broker relationships, and third-party payment handling. Kevin stressed that plans need to think carefully about how easy they are to work with operationally. “The greatest opportunity is to figure out how to establish an integration path with select ICHRA administrators to make sure that you as the health plan are easy to do business with.”
He also warned that operational friction can directly impact visibility and enrollment opportunities if administrators prioritize plans with simpler workflows and stronger integration capabilities.
Why Multi-Market Member Management Matters for Health Plans
The session closed with a broader discussion about member movement across lines of business and the importance of connected operational strategies.
Kevin outlined how consumers increasingly move between Medicaid, Marketplace, ICHRA, and Medicare coverage throughout different stages of life and employment. “These members are moving market to market.”
Rather than treating each transition as a separate relationship, he encouraged plans to think about continuity across the full member lifecycle. “It is a consumer, it is an individual that you are providing coverage for,” emphasized Kevin.
As ICHRA continues to evolve, those capabilities may become increasingly important differentiators for health plans competing in both the Individual and employer-connected markets.
Audience Q&A Highlights
Are rising Marketplace premiums making ICHRA less attractive?
Rising Individual market premiums and subsidy uncertainty continue to create challenges for ICHRA adoption. At the same time, unsubsidized Marketplace enrollment and employers not currently offering coverage remain significant areas of opportunity for ICHRA growth.
The discussion also highlighted the growing number of consumers enrolled in Marketplace coverage without subsidies and the potential for employer-funded contribution models to play a larger role moving forward.
Do health plans need an “ICHRA-specific” product?
No. ICHRA is not a separate health plan product.
Many health plans likely already have ICHRA members enrolling through existing Individual market products today. The larger operational challenge is identifying those members and supporting them differently from traditional direct-to-consumer Individual enrollment.
While plans may eventually tailor certain Off-Exchange experiences to better align with group coverage expectations, specialized ICHRA plan designs are not required to participate in the market.
Why are many plans focused on Off-Exchange ICHRA enrollment?
Operational complexity remains one of the biggest drivers behind Off-Exchange ICHRA enrollment strategies.
Attendees discussed challenges related to subsidy coordination, tax credit confusion, enrollment workflow complexity, and limited visibility into ICHRA enrollment status through Exchange processes. Several organizations noted they currently identify or track ICHRA membership through Off-Exchange workflows instead.
The conversation also highlighted ongoing industry concerns around limited CMS and Exchange-level ICHRA tracking capabilities.
What are the biggest operational challenges in ICHRA today?
Several operational challenges consistently surfaced throughout the discussion, including:
- Payment coordination and premium handling
- Integrating with multiple ICHRA administrators
- Limited reporting visibility into ICHRA enrollment
- Difficulty identifying ICHRA members
- Third-party payment workflows
- Broker and administrator relationship management
- Supporting group-like member expectations within Individual market operations
While many health plans can support enrollment today, billing, payments, administration, and operational coordination continue to be some of the largest gaps across the broader ICHRA ecosystem.
Is ICHRA Right For Your Plan?
Considering whether ICHRA is the right fit for your health plan? Schedule a free consultation with Softheon to review your current operational model, core performance metrics, and market opportunities to determine whether ICHRA is a viable growth strategy for your organization.
From billing and payments to broker distribution and multi-market member management, our team can help you identify the operational gaps and integration strategies needed to support long-term ICHRA success.
