I recently posted about an important reminder Alan Silver gave the audience at the ICHRA Conference in Nashville. It’s a topic that anyone in the ICHRA space has put serious thought to, but as the President of ICHRA at Ambetter, Silver had the data to back it up: not everyone needs a PPO.
 

The point hit in a way that cut through a lot of the noise the industry has been generating around the network question. It’s easy to say that not all employees need a PPO. But most brokers aren’t quite ready to back it up with a client because they don’t have the market-level knowledge they need to prove their point.
 

This month we’re working through what that actually means in practice: how to break down the PPO objection into something answerable, what the state-by-state homework looks like before you make an ICHRA recommendation, and what good ICHRA administration looks like in the room with employees who are choosing a plan for the first time.
 

If any of this maps to a client conversation you’re already navigating, reach out. That’s exactly the kind of conversation we have with brokers every day.

 

The PPO objection sounds simple: “Does ICHRA have PPOs?” But that question almost always means something more specific, and the specific version is what needs an answer. There are at least three different concerns that brokers and clients compress into the same phrase.
 

The first is local access. Employees want to know they can keep their doctors. That’s a question about whether the HMO and EPO options available in your client’s specific market include the health systems employees are already using. If they do, the plan type is largely irrelevant to access. An HMO that includes your region’s major health system gives employees the same access to their doctors and facilities they already have. The plan type is different. The access isn’t. If the networks don’t match what employees need, ICHRA probably isn’t the right answer for that group right now, and it’s worth saying so directly.
 

The second concern stops more implementations than the first: out-of-state access. Individual market plans are built around geography. Traveling salespeople, employees who commute across state lines, C-suite with second homes in another state — these employees need coverage that follows them. That’s a real constraint the individual market hasn’t fully solved, and the honest answer is to say so. It’s also worth noting that some carriers are actively working on this. But right now, a workforce where out-of-state access is a genuine baseline need is a harder ICHRA case, and brokers should know that before they walk into the recommendation.
 

The third concern isn’t really about access at all. It’s about expectation. Employees have been conditioned for decades to see the PPO label as a proxy for good coverage. That framing is deeply embedded — we’ve essentially taught the market to equate PPO with quality, and HMO with compromise. The brokers who handle this well don’t try to argue employees out of the preference. They focus the conversation on what the employee actually needs from their coverage, and let the comparison do the work.
 

The underlying point is this: an individual health plan doesn’t need to work for every employee. It needs to work for that one employee and their family. In most geographies, an HMO or EPO gets that done. The broad network coverage that comes with a PPO sits unused for the majority of plan participants, year after year.

 

 

The reason the PPO conversation stalls isn’t that the individual market doesn’t work. It’s that brokers are trying to answer a local question with a national generalization. ICHRA plan availability, carrier offerings, network footprint, and premium levels all vary significantly by state — and sometimes by county. A broker advising clients in Indiana, Ohio, and Kentucky is working three different individual insurance markets, and a blanket answer about PPO availability doesn’t serve any of them.
 

The specific research that matters: which carriers are active in the ICHRA space in your clients’ markets, both on and off exchange. What the network footprints look like relative to the major health systems in each area. Whether the premium levels make the contribution math work. Off-exchange matters here more than brokers sometimes realize — that’s where several carriers have built ICHRA-specific products with broader network designs than what’s available on the marketplace. Ambetter Health has been doing this work. So has Oscar Health through its dedicated ICHRA division. The market is responding to the network gap, but the pace varies by state.
 

There’s also a timing consideration. Some markets that had limited off-exchange ICHRA options two or three years ago have meaningfully better coverage now. If you evaluated ICHRA for a client in a specific geography and the network picture didn’t work then, it may be worth a second look. The individual market is not static, and the carrier investment going into ICHRA-specific product development has been significant.
 

This is the homework that earns you the right to have a confident conversation. And it’s also where the right ICHRA administration partner helps before you’re in the room. Part of what we do at TWG is take this state-level analysis seriously so brokers aren’t starting from zero every time a client raises the network question.

 

Closing the client is one thing. What happens at enrollment is another. The research on this is consistent: satisfaction outcomes in ICHRA programs drop significantly when employees don’t have adequate support at the point of plan selection. That’s not a product problem, it’s a change management problem that reflects back on the broker.
 

Employees making individual market plan selections for the first time are not well-served by a marketplace login and a list of options. They need someone who can help them think through their actual situation: their doctors, their medications, whether they travel for work, what their family’s usage pattern looks like, and translate that into a plan that fits. That’s the licensed benefit counselor function, and it’s the piece of ICHRA administration that separates a good employee experience from a frustrating one.
 

When evaluating an ICHRA administration partner, four questions matter. First: Do they have visibility into off-exchange plan options in the states you serve, not just on-exchange marketplace plans? Second: Do licensed counselors work directly with employees at enrollment, or does the platform do it alone? Third: How are commissions handled for the originating broker? Fourth: What do payments and compliance infrastructure look like after go-live?
 

Large employer ICHRA adoption grew 34% year over year in 2024–2025, with the 100–199 employee segment growing 49%, the fastest cohort of any size, according to the HRA Council’s most recent data. More than 9 in 10 employers who implemented ICHRA in a prior year renewed it for 2025. Those are employers who got the administration right. The ones who didn’t are in the cautionary-tale column, and most of the cautionary tales trace back to the enrollment experience, not the plan design.
 

TWG is built to function as the back-office layer behind the broker. We don’t own the client relationship. We make it easier to keep. That means doing the state-level market analysis before the recommendation, supporting employees through enrollment with licensed counselors, and staying engaged year-round rather than disappearing after go-live.

The newsletter this month covers the three versions of the PPO objection and what the state-by-state market research looks like before you make a recommendation. The full blog goes further: a breakdown of how to actually run that evaluation for a specific client, a seven-question FAQ built for the conversations that come up after you've made the case, and the specific questions to ask any ICHRA administration partner before you put them in front of a client. If you're in the middle of an active ICHRA conversation, the blog is the more useful place to be.

Ready to Bring this Conversation to your Clients?

Rewiring the ICHRA conversation is going to require a shift in how we talk about market access, and specifically about how we answer and bring up the PPO question. To say there are other options isn’t a dismissal of the concern. It’s an invitation to get more precise about what employees in a specific market actually need from their coverage. That precision is the broker’s job, and it’s also the thing that makes the ICHRA recommendation defensible when a client pushes back.
 

 Andy Stein | Founder & President