Executive Summary: The Broker's Role in the Hybrid Future: Advising Across Level Funded, ICHRA, and Emerging Models
LFP-14.06 — The Broker’s Position#
A 25-person employer in Columbus presents five distinct population segments: fifteen co-located full-time employees who fit the level funded model, five remote employees in states where the PPO network has no contracted providers, three part-time employees below the ACA mandate threshold, a 62-year-old owner, and the owner’s 67-year-old Medicare-eligible spouse. The fully insured broker who presents a single plan to this employer is solving one problem and ignoring four others. The broker who advises across the full complexity, matching each segment to the appropriate model, provides advisory value no single-model broker can match.
The product set available to small employers has expanded substantially. ICHRA has grown over 1,000 percent since its 2020 launch, with small employer adoption up 52 percent from 2024 to 2025 and 83 percent of employers offering ICHRA for the first time in 2025 having not previously offered any coverage. The HRA Council estimates 500,000 to one million lives are now covered by ICHRA or QSEHRA nationally. Association health plans, MEWAs, PEOs, and captive structures each serve specific profiles. The tiered product architecture from Series 15 adds tier selection to model selection, compounding the advisory complexity.
Multi-model advisory requires five knowledge domains: level funded expertise (plan design, stop loss evaluation, TPA vetting, renewal management), ICHRA mechanics (contribution modeling, marketplace quality by geography, class-based structure rules), Medicare coordination (primary and secondary payer rules, interaction between employer coverage and Medicare eligibility), model interaction compliance (ACA class rules, non-discrimination requirements, simultaneous operation of group plans and ICHRA), and tiered model advisory matching employer characteristics to the appropriate product tier.
Most brokers are single-model advisors. The gap creates an opportunity for TPAs that build broker enablement tools covering multi-model analysis, tier recommendation, and ICHRA contribution modeling alongside level funded quoting. It also creates an opportunity for brokers who close the gap, because multi-model capability takes years to build and the HRA Council data showing 92 percent employer retention rates for HRA programs suggests that once employers adopt a multi-model approach, they do not revert. The single-model broker loses complex employers to multi-model advisors at the top and faces digital direct competition for simple employers at the bottom. The brokers who can handle the complexity own the distribution channel for the next decade.