ICHRA for PEOs and Payroll Providers: How to Evaluate and Launch a New Benefits Offering
Learn how PEOs and payroll providers can evaluate ICHRA partnerships, coordinate workforce data, and support employer benefits administration.
Discover how benefits brokers can maintain employer relationships, protect their advisory role, and support clients transitioning to ICHRA.
How benefits brokers can protect employer relationships, maintain their advisory role, and expand their business as clients explore individual coverage arrangements.
For insurance brokers, an employer’s decision to explore an Individual Coverage Health Reimbursement Arrangement (ICHRA) can raise an important concern: What happens to the relationship I have spent years building with this client?
Traditional group health insurance has long provided a familiar framework for benefits brokers. They advise employers on coverage, guide renewal decisions, evaluate costs, and help resolve benefits-related challenges.
ICHRA introduces a different approach. Employers establish defined contributions, while eligible employees select qualifying individual health insurance coverage.
As of November 2026, CMS uses CHOICE Arrangement terminology when discussing ICHRAs. This article uses ICHRA for consistency with the existing regulatory framework and established industry terminology.
As employers explore this model, brokers have an opportunity to remain central to the benefits decision-making process. Maintaining that position requires clear responsibilities, active client engagement, and an understanding of how the relationship will operate after implementation.
Imagine a long-standing employer client approaching its annual group health insurance renewal.
Premiums are increasing, employees have different coverage needs, and leadership wants greater predictability in benefits spending. The employer begins researching alternatives and discovers ICHRA.
If the broker has never introduced or discussed the option, the employer may turn to another adviser or service provider for guidance. That can create a gap in an otherwise established relationship.
Brokers who understand ICHRA can participate earlier, helping employers evaluate whether individual coverage arrangements deserve consideration alongside traditional group insurance.
The conversation begins with the employer’s needs, existing coverage, workforce characteristics, and financial objectives. A broker who can evaluate multiple benefits approaches is better positioned to remain a trusted adviser as those needs evolve.
Under a traditional group health plan, brokers typically help employers compare carriers, assess plan designs, manage renewals, and address ongoing benefits questions.
With ICHRA, the advisory process expands into additional areas. Employers must determine appropriate contribution levels, evaluate individual insurance markets, understand affordability requirements, and establish compliant eligibility structures.
Employees may need assistance understanding available individual coverage options, including provider networks, prescription drug coverage, deductibles, and out-of-pocket costs. The broker’s responsibilities depend on the services the brokerage is authorized and engaged to provide.
For many brokers, the employer-facing role can include:
• Evaluating ICHRA alongside traditional group insurance.
• Advising employers on benefits budgets and contribution strategies.
• Coordinating with compliance professionals on applicable requirements.
• Helping employers understand individual-market conditions.
• Participating in implementation planning and employee communication.
• Reviewing program results and advising on renewal decisions.
Individual policy enrollment and servicing require appropriate licensing and authorization. A broker’s continuing value comes from understanding the employer’s business and helping leadership make informed benefits decisions.
The most important time to establish the broker’s ongoing role is before the employer begins implementing ICHRA.
An employer may work with a third-party administrator to coordinate enrollment, verify qualifying coverage, maintain administrative records, and support reimbursement-related processes. That arrangement introduces additional participants into the benefits relationship.
Clear responsibilities help everyone understand who handles each part of the program. Before proceeding, brokers should establish several expectations.
Who owns the ongoing advisory relationship? The broker and employer should agree on the brokerage’s role in benefits strategy, program reviews, and future decisions.
Who communicates with the employer? Routine administrative questions may go to the administrator, while strategic decisions may involve the broker. Establishing communication protocols helps maintain continuity.
Who assists employees with individual coverage? Licensed insurance professionals may be responsible for plan recommendations, enrollment assistance, and ongoing policy services, depending on their appointments and authorizations.
Who manages compliance and administration? The employer remains the ICHRA plan sponsor. Administrative vendors and professional advisers perform their respective contracted responsibilities.
What information can the broker access? The parties should establish appropriate access to employer-level program information, enrollment progress, administrative updates, and renewal-related records, consistent with applicable privacy and authorization requirements.
How are responsibilities documented? Written agreements should clearly address services, account involvement, compensation where applicable, and ongoing responsibilities.
These arrangements create a practical foundation for maintaining the broker’s role throughout the client relationship.
A successful ICHRA implementation is only the beginning of the employer’s benefits experience.
Workforces change. Employees move, new employees are hired, individual insurance premiums change, and employer budgets evolve. The employer will continue making benefits decisions after the initial enrollment period.
Brokers can remain involved by scheduling periodic reviews and examining whether the arrangement continues to meet the employer’s objectives.
For example, a broker might help the employer evaluate:
• Whether contribution levels remain appropriate.
• How individual-market premiums have changed.
• Whether employees have access to suitable coverage options.
• How workforce changes affect the benefits strategy.
• Whether the employer should continue ICHRA or reconsider other coverage approaches.
These conversations allow brokers to provide ongoing advisory value.
Client retention ultimately depends on the employer’s experience, the broker’s service quality, and the strength of the professional relationship. A clear service model makes continued involvement easier to maintain.
Compensation is an important consideration when a brokerage evaluates ICHRA.
Traditional group insurance and individual-market arrangements may involve different commission structures, licensing requirements, and service responsibilities.
Depending on the arrangement, eligible partners may have opportunities for referral compensation, authorized insurance commissions, or separately contracted advisory services. Referral compensation associated with an administrator’s services is distinct from insurance carrier commissions.
The availability and structure of compensation depend on applicable law, licensing, contractual terms, and the services performed. Brokers should review those details before making commitments or developing revenue projections.
Lirvion offers separate Referral Partner and Broker of Record Partner pathways, with participation and responsibilities governed by the applicable program requirements. Depending on program terms and applicable law, a Broker of Record Partner may have more than one source of compensation.
A brokerage entering the ICHRA market must decide how much operational work to take on. Full-scale administration requires dedicated personnel, reliable processes, and supporting technology.
Lirvion provides technology-supported ICHRA administration designed to help employers and their professional partners coordinate the operational requirements of individual coverage arrangements.
The platform supports structured workflows for employer setup, employee enrollment, coverage verification, eligibility updates, contribution records, and premium-related administration.
For brokers, this administrative infrastructure can help provide greater visibility into the employer’s program and reduce dependence on disconnected communications and manual tracking.
The brokerage’s level of involvement is established according to the employer relationship, applicable authorization, and partnership arrangements.
This approach supports a coordinated working relationship among the employer, broker, licensed insurance professionals, and Lirvion.
As employers renew their arrangements or evaluate changes, the broker can continue participating in strategic discussions while Lirvion supports the contracted administrative processes.
ICHRA may deserve consideration when employers face difficult group insurance renewals, operate across multiple insurance markets, or want to evaluate a defined contribution benefits strategy.
The decision requires an employer-specific review of individual-market coverage, employee costs, affordability, compliance, and administrative needs. Brokers can explore these situations in greater detail in The ICHRA Growth Playbook for Benefits Brokers.
Health benefits strategies are evolving, and employers have more options to evaluate.
As ICHRA becomes part of those conversations, brokers can strengthen their position by developing expertise, defining their responsibilities, and remaining involved throughout the employer’s benefits lifecycle.
Clear agreements, coordinated administration, and continued advisory engagement can help protect established relationships while creating opportunities to serve additional employers.
Lirvion supports this approach through its ICHRA administrative infrastructure and partnership programs for eligible brokers and referral partners.
The question is not whether ICHRA will replace the broker. It is whether the broker will be prepared when an employer asks about ICHRA.
Learn how Lirvion works with benefits brokers and qualified partners to support employer ICHRA programs, coordinate administration, and establish clear professional responsibilities.
Explore how Lirvion helps benefits brokers maintain employer relationships, expand their ICHRA capabilities, and coordinate administration through a structured partnership.