The ICHRA conversation rarely starts with ICHRA. It usually starts with a renewal increase, a workforce spread across several states, or an employer who wants to offer health benefits but cannot make a traditional group plan work.
For a broker, they are opportunities to diagnose the problem more precisely and present a different funding model when the facts support it. That distinction matters. ICHRA should not be positioned as a universal replacement for group coverage. It is a tool, and like any good tool, its value depends on using it in the right case.
Brokers who learn to recognize those cases can protect accounts that might otherwise leave, reopen prospects that have gone quiet, and build a more consultative relationship with employers. The growth comes from better advice, not from forcing every group into the same solution.
Growth starts with the cases the group market is not solving
A traditional group plan can still be the right answer for many employers. But brokers see the same pressure points year after year: volatile renewals, participation problems, limited options for employees outside the employer’s home market, and owners who want a clearer ceiling on benefit spending.
ICHRA changes the structure of that conversation. Instead of selecting one group policy for everyone, the employer defines an allowance and eligible employees select qualifying individual coverage that fits their own circumstances. The employer’s contribution is structured through the ICHRA, while the employee’s coverage is an individual policy or, where applicable, Medicare.
Individual Coverage Health Reimbursement Arrangement
That model can create a useful alternative, but only after the broker has tested the workforce, the local individual market, affordability, and employee impact. What the broker is really selling is confidence in a well-supported decision.
Five signals that deserve a closer look
No single signal proves that ICHRA is the right fit. When several appear together, however, the case is worth modeling.
The employer has absorbed repeated renewal increases and wants a more predictable contribution strategy.
Employees live in multiple states or rating areas, and one group network no longer serves the workforce well.
Participation is inconsistent because some employees already have coverage through a spouse, a parent, Medicare, or another source.
The employer wants to offer a meaningful health benefit but is struggling with group-plan minimum participation or contribution requirements.
Different parts of the workforce have materially different coverage needs, and the employer is open to using permitted employee classes rather than one uniform plan design.
The last point requires care. Federal rules limit employers to defined employee classes. When an employer offers a traditional group health plan to one class and an ICHRA to another, minimum class-size rules may apply. Within each ICHRA class, the arrangement generally must be offered on the same terms, although allowance amounts may vary under the permitted rules based on age and the number of dependents. This is an area where design discipline matters more than sales creativity.
Do not lead with price. Lead with the employer’s problem
The quickest way to weaken an ICHRA recommendation is to present it as a cheaper version of group insurance. Sometimes the employer’s total cost improves. Sometimes it does not. Even when the numbers are favorable, cost is only one part of the decision.
A credible broker starts by asking what the employer is actually trying to fix. Is the concern budget volatility? Network access? Recruiting? Participation? Administrative burden? A difficult geographic mix? Once the problem is clear, the broker can compare the current group plan and a proposed ICHRA against the same set of priorities.
A useful broker rule: If the recommendation only works when every employee behaves like an average employee, the analysis is not finished.
A broker-led ICHRA sales process
1. Qualify the employer before building a proposal
Start with the current plan, employee census, work locations, eligibility rules, renewal history, employer contribution, and the employer’s decision timeline. If the underlying data is weak, the proposal will be weak too.
This first pass should also surface disqualifying facts or operational concerns early. A broker gains credibility by saying, “This may not be the right case,” before asking the employer to invest time in a full comparison.
2. Map the workforce, not just the headcount
Two employers with 40 employees can have completely different ICHRA outcomes. Age distribution, household composition, employee locations, Medicare eligibility, and current coverage sources all influence the design and employee experience.
The census becomes the working map of the case. Clean data allows the broker and administrator to test permitted classes, model allowances, review affordability, and identify locations where individual-market options need a closer look.
3. Test the real individual market
An allowance that looks reasonable in a spreadsheet may feel very different when employees compare actual plans. Review carrier participation, networks, provider access, deductibles, metal levels, and the premiums employees are likely to see in their rating areas.
This is where experienced ICHRA advice becomes visible: the broker tests whether the proposed benefit can produce a workable coverage experience across the workforce.
4. Explain the tax-credit interaction before enrollment
An ICHRA offer can affect eligibility for the federal premium tax credit. If the offer is affordable under the applicable federal test, the employee generally cannot claim a premium tax credit for Marketplace coverage, even after opting out.
If the offer is unaffordable, the employee may qualify for the credit by opting out of the ICHRA and waiving future reimbursements, provided the employee meets the other eligibility requirements.
Employees should understand that relationship before they select coverage. It belongs in the benefit conversation before enrollment and should be communicated in plain language without drifting into individual tax advice.
5. Define ownership before the launch
Many implementation problems are not regulatory problems. They are ownership problems. Employees do not know whom to call, the employer assumes the broker is handling enrollment questions, and the broker assumes the administrator is following up on missing coverage documents.
Before launch, write down who owns plan design, notices, employee education, plan shopping support, coverage verification, premium-payment records, reimbursements, escalations, and renewal review. The smoother the handoff, the more likely the employer is to view ICHRA as a managed benefit rather than a collection of separate tasks.
Questions that move the conversation forward
The best discovery questions are specific enough to reveal a problem but neutral enough that the employer does not feel pushed toward a predetermined answer.
What changed at the last renewal, and which part of the change created the most concern?
Where do employees live, and are there locations where the current network is consistently weak?
How many eligible employees waive the plan, and do you know why?
Is the employer trying to cap spending, improve employee choice, or solve both problems?
Are there employee groups with genuinely different working conditions or coverage needs?
How much enrollment support will employees need, and who should provide it?
What would make the employer consider the first year successful?
Where promising cases go wrong
Most failed ICHRA conversations do not fail because the concept is too difficult. They fail because someone skipped a practical step.
The broker promises savings before reviewing individual-market premiums and employee impact.
The allowance is chosen as a round number instead of being tested against affordability and local coverage costs.
The employer uses workforce categories that do not line up with the permitted federal classes.
Employees hear “more choice” but receive too little help understanding plans, networks, and deadlines.
The premium tax credit is mentioned too late, after employees have already formed expectations about Marketplace subsidies.
No one owns the follow-up when enrollment or coverage verification is incomplete.
A strong administrator can reduce those operational gaps, but the broker still sets the tone. Employers remember whether the recommendation felt controlled, candid, and prepared.
What an ICHRA partner should make easier
The broker should remain the strategic adviser. The administration partner should make the arrangement easier to operate and easier to see.
In practical terms, that means supporting plan setup, affordability inputs, employee eligibility records, required communications, enrollment pathways, coverage substantiation, premium-payment tracking, reimbursement administration, reporting, and follow-up on open items. It also means giving the broker enough visibility to answer the employer’s questions without chasing updates across disconnected systems.
Lirvion is designed around that division of labor. Brokers can stay close to the client relationship while the platform and support team handle the recurring ICHRA administration that otherwise consumes the account team. That division of labor gives the broker a better process to lead while preserving the client relationship.
The real growth opportunity is trust
ICHRA can help a broker win new business, but the more durable opportunity is becoming the person an employer calls when the standard answer no longer fits. That position is difficult for competitors to displace.
The brokers who build that position tend to do three things well. They qualify carefully, they show the tradeoffs without overselling them, and they stay involved after implementation. Over time, that approach strengthens the advisory relationship and gives the broker a repeatable way to serve employers that the traditional group market is leaving frustrated.
Sources
IRS final-rule materials: https://www.irs.gov/irb/2019-28_IRB
Employer eligibility, permitted employee classes, same-terms rules, minimum class-size requirements, integration requirements, and premium tax credit treatment.
U.S. Department of Labor ICHRA model notice: https://www.dol.gov/agencies/ebsa/laws-and-regulations/rules-and-regulations/completed-rulemaking/1210-ab87/individual-coverage-model-notice
Employee notice framework and explanation of ICHRA coverage and premium tax credit considerations.
CMS: Health Reimbursement Arrangements: https://www.cms.gov/marketplace/private-health-insurance/health-reimbursement-arrangements
Overview of how ICHRAs may reimburse individual health insurance premiums and support employer and employee flexibility.
DOL model attestations: https://www.dol.gov/agencies/ebsa/laws-and-regulations/rules-and-regulations/completed-rulemaking/1210-ab87/individual-coverage-model-attestation
Annual and ongoing substantiation requirements for individual coverage or Medicare.
Compliance note
This article is educational and marketing content, not legal or tax advice. Final plan design, affordability methodology, notices, employee-class structure, and participant communications should be reviewed for the facts of the employer’s case and current federal and state requirements.
Have an employer case that may be a fit for ICHRA?
Bring the census and the employer’s priorities. Lirvion can help you evaluate the case, structure the program, and support the rollout.