Interview: The ICHRA Opportunity for Agents

There are three main regulatory or legislative items we have coming to a head, at the same time, that will impact plan year 2026 and 2027, along with a few changes that have gone into effect as of August 25.

1. We have the 2025 Marketplace Integrity and Affordability Rule, which was finalized in June.
2. We also have the One Big Beautiful Bill Act with the ACA legislation within that, that was finalized in July [2025].
3. And the enhanced subsidies that have been in place in the ACA market since 2021, originally renewed in 2022 through the end of 2025 … are set to expire as of December 31 of this year…

A couple of those main changes include:

• The 150 percent federal poverty level SEP that ended on August 25…
• Individuals will not be able to gain access to premium tax credits based on their income alone. So, they would have to have another qualifying life event to gain access to that.
• Tightening up timeframes for data matching inconsistencies no longer accepting an attestation of household income for self-employed individuals…
• Also, for immigration statuses, the DACA recipients are no longer eligible to enroll as of August 25 through the marketplace…
• If you have someone who’s at a zero premium today who is renewing at zero premium for 2026, if they do not actively update and renew their application, they will have a monthly $5 premium responsibility until they go in and update their application…

If you have clients you can’t get in touch with, or who normally just passively renew because things have been status quo, it will not be status quo for 2026.

Just as those changes are going to impact your members, you need to be able to educate them and understand what those changes mean for you…

Make sure you’re contracted and certified early this year, and contracted with all of the available options in your market, if possible. We don’t know what premium rate increases are going to look like yet.

Insurers had until August 13 to file their premium rates for 2026. So, while you can look at what rates have been filed, those can also be changed again. We may not know the full look of the landscape until sometime in October, or even November 1 in some cases.

We may not know the full look of the landscape until sometime in October, or even November 1 in some cases… whatever you can be doing today to set yourself up for success is going to be important.

Contracting and certification start to take a lot longer as we get closer to AEP and OEP. So, whatever you can be doing today to set yourself up for success is going to be important.

Carriers are going to be hosting trainings and providing additional resources. We know carriers are also going … to educate members a little bit more so that they understand the importance of actively renewing but also understand the importance of insurance.

Because there are going to be individuals who are making a choice this year between maintaining their coverage and paying a higher premium, or considering going without … a key role of the brokers and agents this year is presenting the value of insurance and communicating to their members the importance of actively renewing and providing accurate data.

ICHRA stands for individual coverage Health Reimbursement Arrangement.

It allows an employer to move from a defined benefit type of offering to a defined contribution type solution. When an employer offers an ICHRA solution to their employees, it really unlocks the flexibility for both the employer and the employee.

When an employer offers an ICHRA solution to their employees, it really unlocks the flexibility for both the employer and the employee.

With group producers … you’re primarily focusing on your traditional group offerings. Year over year, brokers and employers have experienced significant rate increases and they’re in many scenarios of running out of solutions.

And so, [for] the brokers who are traditionally focused in the group space, this gives them the ability to provide an alternative or an additional type of product to their clients. [One] that allows them to retain that client with net new solutions and reduce costs for their employer. It also allows them to draw in new clients where perhaps they may not have had an opportunity before. Group brokers are skilled in positioning products to employers. They have existing relationships. They know how to target individual employers directly. This is just a nice new product that they can offer.

And on the individual side…individual brokers are typically used to selling individual policies, whether it be through carriers, directly through ACA plans, things along that line.

What’s unique about ICHRA is brokers who are typically versed with individual products know how to service the employee and help them make those individual benefit elections that uniquely support their needs.

Brokers who are typically versed with individual products know how to service the employee and help them make those individual benefit elections that uniquely support their needs.

Where they can diversify is looking for opportunities to expand their reach by marketing an ICHRA solution to employers and leveraging their experience in the individual market and how they take care of the employee experience.