The Broker's Role in the Hybrid Future: Advising Across Level Funded, ICHRA, and Emerging Models

A 25-person company in Columbus, Ohio presents the following workforce to its broker at renewal. Fifteen full-time, co-located employees fit the level funded model well: stable employment, predictable utilization, accessible in-network providers. Five employees work remotely from three different states where the employer’s PPO network has no contracted providers, making level funded impractical for them and ICHRA the better fit. Three part-time employees work fewer than 30 hours per week, below the ACA mandate threshold, and receive no coverage. The 62-year-old owner and the owner’s 67-year-old spouse need different products entirely: the owner needs level funded or ICHRA; the spouse, who is Medicare-eligible, needs a Medicare Supplement or Medicare Advantage plan that coordinates with whatever the employer offers.

This is not an unusual employer. It is a common employer whose complexity is typically managed by ignoring it. Everyone goes on the same fully insured plan. The remote employees deal with the network problem by seeking out-of-network care and paying more. The part-time employees get nothing. The owner’s spouse buys individual Medicare supplemental coverage without any coordination with the employer’s plan. The fully insured broker who presents a single plan to this employer is solving one problem (the 15 co-located employees) and ignoring four others.

The broker who advises this employer on the full complexity, matching each population segment to the appropriate model, is providing advisory value that no single-model broker can match. The advisory complexity is the opportunity. It is also the barrier.

The Multi-Model Product Set

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The product set available to a small employer has expanded substantially over the past five years. Level funded plans serve employers with stable, co-located populations who benefit from claims transparency and surplus potential (LFP-01.01). ICHRA, which has grown over 1,000 percent since its 2020 launch according to the HRA Council, allows employers to provide tax-free contributions for employees to purchase individual coverage on the ACA marketplace (LFP-08.01). ICHRA adoption among large employers (50-plus employees) grew 34 percent from 2024 to 2025, with some cohorts showing 49 percent year-over-year growth. Small employer ICHRA adoption grew 52 percent in the same period. The HRA Council estimates that between 500,000 and one million lives are now covered by an ICHRA or QSEHRA nationally. Meanwhile, 83 percent of employers offering ICHRA or QSEHRA for the first time in 2025 had not previously offered any coverage, making ICHRA an on-ramp to benefits for employers historically locked out of the group market.

Association health plans (LFP-08.03), MEWAs (LFP-08.04), PEOs (LFP-08.05), and captive structures (LFP-08.07) each serve specific employer profiles. The tiered product architecture from Series 15 adds tier selection (Core, Plus, Black) to the model selection, compounding the advisory complexity. For the employer with the Medicare-eligible spouse, the broker needs to understand Medicare primary and secondary payer rules, group Medicare Supplement options, and the interaction between employer coverage and Medicare (LFP-16.01).

The product set is no longer a menu of two or three fully insured carriers. It is a matrix of funding models, coverage structures, and regulatory frameworks that interact differently depending on the employer’s workforce composition, geographic distribution, employee classification structure, and risk tolerance.

What Multi-Model Advisory Requires

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Level funded expertise is the core requirement and the subject of this entire series. Plan design, stop loss evaluation, TPA vetting, claims analysis, and renewal management (LFP-14.05) are the baseline capabilities. Without them, the broker cannot serve the 15 co-located employees in the Columbus example.

ICHRA mechanics represent the second knowledge domain. The broker must understand how ICHRA works: the employer sets a defined contribution per employee class, the employee selects an individual ACA-compliant plan on the marketplace, and the employer reimburses qualified expenses up to the contribution amount. The class-based structure allows different contribution levels for different employee classes (full-time, part-time, salaried, hourly, geographic). The broker advising an employer on ICHRA for remote employees must understand the individual marketplace quality by geography (LFP-07.05), because the ICHRA is only as good as the marketplace plan the employee can buy. An employee in a market with one marketplace carrier and limited plan options receives a structurally different benefit than an employee in a market with 13 carriers and dozens of plan choices, even if the employer’s ICHRA contribution is identical. Remodel Health, Take Command Health, and other ICHRA administration platforms offer certification programs, but broker uptake remains limited relative to the scale of the opportunity.

Medicare coordination is the third knowledge domain. For the employer with employees or owner-spouses aged 65 and older, the broker needs to understand Medicare primary and secondary payer rules, how employer coverage interacts with Medicare eligibility, what happens when an employee turns 65 while covered under the employer’s level funded plan, and the tax treatment implications from Series 16. This is a different knowledge domain from group benefits. Most benefits brokers who serve the under-65 market do not advise on Medicare. Most Medicare brokers do not advise on group benefits. The employer with both populations needs a broker who spans both domains or a coordinated advisory team that covers both.

Model interaction is the fourth knowledge domain. Can the employer offer level funded to one class and ICHRA to another? Yes, with ACA class-based structure rules that define permissible employee classes. What are the compliance requirements for operating both simultaneously? The employer must satisfy ACA affordability and minimum value requirements for employees not offered ICHRA. The employer cannot offer both a group plan and an ICHRA to the same employee class. Non-discrimination rules apply. The employer who offers level funded to full-time employees and ICHRA to part-time employees must structure the classes correctly to avoid ACA violations. The broker who cannot explain these interaction rules cannot advise a multi-model employer.

Tiered model advisory adds a fifth layer. When the product architecture from Series 15 introduces tier selection alongside model selection, the broker must help the employer select both the model (level funded, ICHRA, hybrid) and the tier (Core, Plus, Black) for each employee segment. The tier selection depends on the employer’s population characteristics, risk tolerance, and willingness to invest in cost management programs. The broker who can explain why the 30-person construction company belongs in Core (cost-focused, standard networks, basic reporting) while the 25-person professional services firm belongs in Plus (enhanced analytics, broader network access, care navigation) is providing tier advisory that requires understanding both the product architecture and the employer’s operational reality.

The Capability Gap in the Current Broker Market

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Most brokers are single-model advisors. They sell fully insured, or they sell level funded, or they sell ICHRA. The number of brokers who can competently advise across all three models and manage their interaction for a single employer is small. The ICHRA market’s rapid growth has produced specialized ICHRA brokers and platforms, but few of them have deep level funded expertise. The level funded specialists described in 14.05 rarely have ICHRA certification or experience. The Medicare brokers operate in a separate distribution channel entirely.

The gap creates an opportunity for TPAs. The TPA that builds broker enablement tools, including multi-model analysis frameworks, tier recommendation engines, compliance guidance for multi-model employers, and ICHRA contribution modeling alongside level funded quoting, removes the capability barrier from its distribution channel and converts broker limitations into TPA-solved problems. Series 15.08 addresses this directly. The TPA that equips its broker partners to advise across models captures employers that single-model brokers cannot serve.

The gap also creates an opportunity for the brokers who close it. The multi-model advisory capability is a competitive moat because it takes years to develop the knowledge across all three domains. The broker who invests in level funded depth (14.05), adds ICHRA certification and marketplace expertise, and develops Medicare coordination knowledge is building an advantage that compounds as the market moves toward multi-model solutions. 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 to single-model coverage. The broker who manages the transition owns the relationship for the long term.

What Happens to the Single-Model Broker

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The single-model broker does not disappear immediately. They lose the complex employers first: the multi-segment, multi-location, multi-generation employers who need multi-model solutions. They retain the simple employers: the 15-person single-location company where all employees are full-time, co-located, and under 55, and where a single level funded plan serves the entire population.

But the simple employers are the employers most vulnerable to direct channel distribution (LFP-15.09). If the TPA builds a digital enrollment platform that serves simple employers without a broker, the broker’s remaining market is the complex multi-model employers they are not equipped to serve. The trajectory narrows the viable broker practice from both ends: increasing advisory complexity at the top (multi-model, multi-tier, multi-geography employers who need integrated advice) and increasing digital direct competition at the bottom (simple groups that can be served through a technology platform without a broker intermediary).

The brokers who survive and grow are the ones who can handle the complexity. The single-model broker who sells level funded to simple employers today is building a practice that can be disintermediated by technology. The multi-model broker who advises complex employers across level funded, ICHRA, and hybrid configurations is building a practice that technology strengthens rather than replaces, because the advisory complexity exceeds what any current platform can automate.

The hybrid future requires a broker who can advise across models. The single-model broker loses the complex employers who need integrated solutions and faces digital competition for the simple employers who do not need a broker at all. The broker’s role in the hybrid future is advisory at a level most current practices are not equipped to provide. The brokers who build that capability own the distribution channel for the next decade. The ones who do not will find that the market has moved past them, not because the market changed suddenly, but because the product set expanded while their capabilities did not.