April 2026 | By Lindsey Miller
Key takeaways for health plans:
- ICHRA enrollment is driven by behavior, not new products.
- Plans that align plan design, pricing, and networks to member preferences will outperform those leading with lowest-cost options.
- Brokers and ICHRA vendors directly impact conversion, compliance, and long-term retention.
Let’s clear something up: there is no such thing as an “ICHRA plan.”
Individual Coverage Health Reimbursement Accounts (ICHRAs) are not a new line of business or a special product sitting next to Bronze, Silver, or Gold. ICHRA members enroll in the same Individual market plans as everyone else. What’s changed is how people come into the experience and what they expect it to feel like.
For brokers, this is where a lot of conversations start to drift. Employers ask what “ICHRA plans” they should be offering. Health plans ask how to position their “ICHRA products.” But nothing new has been added to the shelf. The same plans are there. What’s changed is who is shopping, and how they make decisions.
Why ICHRA Growth Is Reshaping Member Expectations
Most ICHRA enrollees are not traditional Individual-market consumers. They’re coming from employer-sponsored group coverage. That shapes their expectations. They will demand:
- Predictable copays
- Familiar provider networks
- A sense of “group-like” stability
When health plans treat ICHRA as just Individual enrollment, they miss this behavioral shift.
You can see it almost immediately when someone starts shopping. A member who has been on a group plan for years doesn’t approach the experience like a typical individual-market shopper. They’re not starting from scratch. They’re comparing everything to what they had before.
That’s where a lot of friction comes in. Someone used to copays is suddenly looking at a high deductible. Someone who has always had broad access is now being asked to think about network tiering. Even when the pricing makes sense, it doesn’t always feel right to the member.
This is where brokers end up spending the most time. Not just walking through options, but translating the differences and helping people relearn what “good coverage” looks like in a new model.
ICHRA is starting to feel a lot like a 401(k). The employer sets the contribution, and the employee is responsible for choosing how to use it. That shift sounds simple, but it puts a lot more pressure on the decision-making moment.
In a 401(k), people rely on tools, guidance, and advisors to make confident choices. ICHRA is no different. If anything, the stakes feel higher because it is tied to access to care.
Health plans have a role to play here. Not just in the plans they offer, but in how they support the broker channel. Brokers are the ones guiding these decisions. They are not optional in the process.
That means investing in broker tools. Shopping experiences that make plan differences clear. Side-by-side comparisons. Workflows that allow brokers to stay involved throughout the process and maintain their broker of record status.
When that support is there, the experience feels guided. When it is not, brokers are left filling the gaps manually, and that is where decisions slow down or fall apart.
Building a Plan Portfolio That Supports ICHRA Enrollment
The ICHRA population is mixed by design.
Within a single employer contribution structure, you may have a 26-year-old single employee, a family with young children, and a 60-year-old nearing Medicare eligibility all shopping with the same defined contribution.
That reality plays out in very different ways during enrollment. Some employees are comfortable optimizing for premium and taking on more risk. Others are looking for something that feels as close as possible to their previous group plan, even if it costs more.
If a health plan’s strategy is “lead with the lowest premium Bronze plan,” they risk losing share — and margin — because that approach ignores traditional and “safe” group preferences.
Narrow network, high-deductible plans tend to attract younger, more price-sensitive members. Copay-driven Silver designs resonate more with those coming from traditional group coverage. And in some cases, employers are deliberately setting contributions at a level that encourages enrollment into richer Gold plans because they want more predictability for their employees.
From a broker perspective, this is where placement gets won or lost. It is not about having one “best” plan. It is about having a portfolio that actually maps to how different employees think about coverage.
One size fits all isn’t efficient. It’s a growth limiter.
ICHRA Compliance and Strategy: Why It’s a Funding Model, Not a Product
Successful carriers understand this distinction. They don’t build an “ICHRA plan.” They build an Individual market portfolio that mirrors group expectations.
That means:
- Plan designs that feel familiar to former group members
- Network configurations aligned to employer geographies
- Pricing strategies that anticipate defined contribution dynamics
The mistake is reacting too quickly and trying to engineer an “ICHRA-friendly” portfolio from scratch. The smarter approach is to start where you already have strength in the group market. Look at the plans members are choosing. And watch how those preferences translate when those same populations move into ICHRA.
SureCo cited that 86% of ICHRA-funded members changed plans year over year, but 72% stayed with the same carrier. Year one is often about getting something in place; year two is where people start making more informed decisions once they understand how the market works.
That has real implications for how health plans think about 2027 and beyond. Instead of trying to predict the perfect portfolio upfront, there is an opportunity to learn from selection behavior. Which plans are people moving into after their first year? Where are they trading up for richer benefits? Where are they pulling back on premium?
Members should not feel like they are starting over. They should feel like they are choosing between options that resemble what they already understand, just within a different funding structure.
Winning ICHRA Growth: What Brokers and Carriers Need from ICHRA Vendors
As ICHRA adoption grows, the winners won’t be the carriers with the cheapest plan.
They’ll be the health plans who:
- Understand enrollment behavior shifts
- Track selection patterns in real time
- Adjust plan mix to protect margin while expanding share
Brokers see this play out very clearly. Some carriers are consistently easier to place business with because their portfolio “fits” the population. Others create friction, even if the pricing is competitive, because the plans do not align with what employees are expecting.
ICHRA growth means offering the right mix of familiar options within a new funding model.
If you want to keep up with how this is evolving, you can connect with me on LinkedIn. I’m always sharing ICHRA hot takes and posting about upcoming speaking engagements.
Drop me a line if you’re as excited about where this is going as I am.
