ICHRA at the Forefront: What to Expect in 2025 and Beyond
In the grand Technology Adoption Lifecycle, ICHRA currently occupies the cutting edge—teetering between the innovators and early adopters. While the market may still seem small, with roughly half a million employees covered compared to over 150 million on traditional group plans, the momentum is undeniable. The year 2024 marked the “Great ICHRA Awakening,” and 2025 promises to propel Health Reimbursement Arrangement adoption to exciting new heights.
Understanding the Technology Adoption Lifecycle
Before diving into the trends shaping ICHRA’s future, it’s worth reflecting on the recent surge of innovation. The emergence of new ICHRA administration platforms signals a growing embrace of the defined contribution model among employers nationwide.
At Take Command, we welcome the healthy competition that drives platforms to innovate and improve service—after all, a rising tide lifts all boats.
In 2024, ICHRA became a major growth engine for some of the largest individual insurance players, with insurers like Oscar and Ambetter weaving ICHRA into their long-term strategies. This isn’t just a niche for individual-focused insurers anymore; healthcare providers across the country are eyeing ICHRA as a strategic opportunity to position themselves for success in this emerging healthcare paradigm. Even state-based healthcare exchanges are beginning to engage actively with the evolving ICHRA ecosystem.
With all this momentum building, the big question is: what’s next for ICHRA? Here are three predictions for 2025, informed by recent developments and current trends.
1. Policymakers Lean into ICHRA
One of ICHRA’s greatest strengths is its bipartisan appeal. Originally introduced during the first Trump administration, ICHRA gained further momentum under the Biden presidency. Now, with Republicans controlling both houses of Congress, there’s renewed interest in shaping policy that supports its growth.
In December, the House Ways and Means Committee sought expert input on ICHRA policy improvements. Take Command responded with a comprehensive letter outlining ways to enhance the program, backed by real stories from benefits consultants and HR professionals. It’s encouraging to see policymakers listening and engaging with the industry.
Meanwhile, Indiana’s pioneering HRA tax credit for small businesses (under House Bill 1004, “Healthcare Matters”) sets a promising precedent. This program offers tax incentives for employers with fewer than 50 employees who adopt HRAs instead of traditional group insurance. Inspired by Indiana’s success, other states—like Ohio, Texas, and Georgia—are now exploring similar proposals. We’ll be watching closely.
2. Carriers and ICHRA Platforms Smooth the Path
The “chasm” in the Technology Adoption Lifecycle—the critical gap between early adopters and the early majority—is just ahead for ICHRA. Crossing this divide will hinge on making the employee experience seamless and simplifying change management for employers.
Collaboration with health insurance carriers to tackle challenges such as billing, enrollment, and employee communications will be vital to delivering a first-class user experience.
Recently, Take Command partnered with fellow ICHRA administrators zizzl and Remodel Health to develop a white paper titled “The ICHRA Model & Health Plans: Planning for Operations & Member Experience Success.” This document aims to kickstart a broader industry dialogue on best practices for policy design and member experience. In the coming months, we plan to invite more ICHRA platforms to join this conversation—a crucial step toward refining and scaling top-tier ICHRA experiences.
Curious about what we’ve been working on? Check out the Future of ICHRA project for a sneak peek!
3. Growth Momentum Will Accelerate
Looking ahead, ICHRA adoption is poised to accelerate, though predicting exact growth rates remains tricky. What’s clear is that ICHRA’s expansion is outpacing most expectations—with no signs of slowing down.
The HRA Council, a nonpartisan advocacy group dedicated to education and awareness around defined contribution health coverage, remains an invaluable resource for tracking market growth. Take Command is proud to be a founding member of this coalition, which brings together insurers, brokers, administrators, employers, and support organizations to share insights.
Each year, the Council publishes an ICHRA adoption report based on aggregated, anonymized data from leading platforms—including Take Command. In my view, this report offers the most comprehensive and reliable window into the market’s pulse. Preparations for the 2025 edition are already underway—so stay tuned for fresh insights soon.
Final Thoughts
ICHRA is moving from the fringes to the forefront of healthcare benefits innovation. With bipartisan support, growing carrier collaboration, and accelerating adoption, 2025 could be a breakout year that transforms how employers offer health benefits.
At Take Command, we’re excited to be part of this journey and committed to helping employers and employees navigate this evolving landscape with confidence. Watch this space as we share more updates and insights in the months ahead!