This month, ICHRA got something it has rarely had in the health policy world: unanimous bipartisan support in a national legislative body. The NCOIL Spring Meeting in Louisville put a model ICHRA tax credit bill on the agenda — and the interest coming from both red and blue state legislators is about as unified as healthcare policy gets.
That signal matters for your clients. When a skeptical CFO asks 'what if this goes away,' the answer has never been stronger. Here's what's happening, what it means for your book, and how to make it part of a conversation you should already be having.
POLICY UPDATE
ICHRA was created by a Trump administration rule in 2019. The Biden administration could have reversed it and chose not to. Now Republicans and Democrats are actively competing to build on it — and that trajectory accelerated this month.
The NCOIL model bill vote
The National Conference of Insurance Legislators held its Spring Meeting in Louisville this week (April 16-19). On the agenda: continued consideration of the NCOIL ICHRA Model Act, sponsored by Ohio Rep. Meredith Craig. NCOIL CEO William Melofchik told Politico in March that state interest is 'pretty strong' and comes from 'a rare red and blue state mix' including Florida, New Jersey, and Texas. A model law, once adopted, gives any state a ready-made legislative template — which is how ICHRA tax credit activity spreads quickly across statehouses.
State tax credits: where things stand right now
The state-level pipeline is the most immediate story for your clients, especially those in smaller employer groups. Here is a quick summary of where legislation stands:
Indiana — Enacted. $400 per employee in year one, $200 in year two. Available now for employers with fewer than 50 workers.
Mississippi — Both chambers passed their respective bills by February 2026. Modeled on Indiana's approach.
Wisconsin — Assembly passed February 2026. Senate companion bill in committee.
Ohio HB 133 — Passed the House unanimously. Awaiting Senate action. Sponsored by Rep. Craig, the same legislator driving the NCOIL model bill.
Georgia HB 341 — Credits up to $600 per employee for employers with 10 or fewer workers. Passed the House in 2025.
Connecticut — Democratic Gov. Lamont included an ICHRA tax credit in his 2026-27 budget request, calling it a tool to reduce Medicaid rolls and help small businesses.
For a 30-person company in Indiana, that's up to $12,000 in year-one tax relief. That's not a long-term benefits strategy argument — it's a number you can put in front of business owners and CFOs today. If your clients are in any of these states, the conversation starts there.
The market conditions backing policy changes up
The policy momentum is landing at exactly the right time. The KFF 2025 Employer Health Benefits Survey found average family premiums hit $26,993 — up 6% year over year, the third straight year of 6%+ increases. Mercer projects average employer health costs will exceed $18,500 per employee in 2026. Employers are hurting and they're looking for alternatives.
Meanwhile, enhanced ACA subsidies expired at the end of 2025, pushing marketplace enrollment down by more than a million people. Employers with uninsured workers are scrambling for coverage options. ICHRA is near the top of the list.
The HRA Council's 2024-2025 Growth Trends report puts total ICHRA and QSEHRA enrollment between 500,000 and 1 million people — over 1,000% growth since 2020. Large employer adoption grew 34% year over year. And 83% of new ICHRA adopters had never previously offered health coverage at all. This market is expanding, not just shifting.
What the data actually says:
That 87% figure is the one worth sitting with. The clients who left aren't necessarily going to a competitor. They're going to a broker who showed up with a different answer. The policy tailwind and the market conditions are both pointing in the same direction. The question is whether you're already fluent.
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The ICHRA Ancillary Checklist
ICHRA solves the medical cost problem. But the moment you move a client off group, a new question shows up: what happens to dental, vision, life, disability, and voluntary benefits?
Most ICHRA platforms weren't built to handle ancillary benefits. That's not a design flaw you can work around. It's a structural gap that has to be planned for before enrollment, not after.
Use this checklist before every ICHRA transition. It covers four areas:
Enrollment Setup — Is dental and vision running through one system or two? Are all carrier connections established before go-live? Are new hire timelines aligned?
Employee Experience — Will employees use one enrollment platform or two? Can they see all elections in one place after enrollment closes? Do they have access to a licensed person to explain their options?
HR and Administration — Is there one point of contact for ancillary questions? Is there a clear process for qualifying life events, mid-year changes, and terminations?
Open Enrollment Coordination — Are all benefit lines running on the same enrollment window? Does the communication plan cover the full package, not just the ICHRA piece?
If you're finding boxes you can't check, that's the conversation to have now — not during open enrollment.
A complete ICHRA and ancillary setup means one platform, one enrollment experience, one point of contact for HR and brokers. That's what TWG's SYNC Service delivers.
Your client sets the contribution. Their employees shop individual market plans. You're the broker who moved them off the group renewal rollercoaster and into a predictable, budget-controlled model.
Ancillary Benefits Administration (SYNC Service)
Dental, vision, life, disability, voluntary benefits — all alongside ICHRA in one seamless enrollment experience. Your client's HR team manages everything in one place. You have one point of contact for every benefit line.
Year-Round Benefits Communication
Licensed benefit counselors — on-site at major locations during enrollment, available via call center year-round — guide employees through their options in plain language. No commission. No upselling. Just clear answers.
"Having all our benefits in one system with the right level of support transformed our open enrollment process."
— Benefits Administrator, TWG Client
Have a client who's looking at ICHRA and wondering what happens to the rest of the benefits package?
That's exactly the conversation to have before enrollment.
Both parties are moving toward ICHRA. State legislatures are building financial incentives around it. Employer health costs are at a 20-year high. And 87% of brokers who didn't present it lost a client because of it.
This post covers the policy landscape, the market conditions driving demand, what to look for in ICHRA vendors, and — importantly — how to be honest with clients about the limitations. The clients who trust you with the full picture are the ones who stick.
What this post covers:
Why the bipartisan policy momentum is real — and how to use it in the client conversation
The state tax credit landscape and which states have active legislation right now
The market conditions (cost, ACA subsidy expiration, adoption data) that make the timing right
What separates strong ICHRA vendors from platforms that disappear after go-live
The real limitations of ICHRA — and why being upfront about them protects your credibility
We work with benefits brokers and consultants who are done watching their clients absorb double-digit renewal increases and hoping for a different result. ICHRA isn't right for every client — and we'll tell you that upfront. But for the clients where it fits, there's no better time to have that conversation than right now.
We've completed more than 250 ICHRA implementations. We speak broker language because we work in your world every day. And the path is straightforward: tell us about the client, we'll assess the fit, design the right solution, and handle white-glove implementation from start to finish — while you stay in front of the relationship.
The path is straightforward: Tell us about the client. We'll assess the situation, design the right solution, and handle white-glove implementation from start to finish — while you stay in front of the relationship.
