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- Unpacking ICHRA with Amanda Harlan from Sandbox Advisors
Unpacking ICHRA with Amanda Harlan from Sandbox Advisors
Exploring the potential and challenges of ICHRA, from employer adoption to employee experience.
Claire Trautz
August 08, 2025
I’ve been spending a lot of time diving into all things ICHRA, reading, learning, and connecting with folks who have deep expertise in the space. A few weeks ago, I published the transcript from my conversation with Ryan Koo where we covered ICHRA from both the broker and employer lens. More recently, I had the opportunity to sit down with Amanda Harlan from Sandbox Advisors, the advisory arm of Sandbox Industries, a strategic investment and advisory firm focused on healthcare and insurance. Over the past few years, Amanda has become a leading expert on ICHRA, and I was thrilled to have the chance to learn from her.
Below, you’ll find some background on why I find this space so fascinating, the questions I asked Amanda, and the full interview. Don’t sleep on ICHRA, this is definitely a space to watch, and one I’ll continue to cover. If you’re an expert in the field and would like to share your perspective on ICHRA, please reach out, I’d love to connect.
Thanks for being here!
-Claire
Background
The Individual Coverage Health Reimbursement Arrangement (ICHRA) is quickly becoming one of the most talked-about solutions in the employee benefits space, as employers and insurers are seeking ways to adapt to rising healthcare costs and increasing demand for more flexible, consumer-driven healthcare options. ICHRA allows employers to provide their employees with a defined contribution to purchase individual health insurance coverage through the marketplace, offering greater flexibility than traditional group plans.
What makes ICHRA particularly interesting right now is the growing momentum behind it. According to recent reports, ICHRA adoption has surged by more than 1,000% since 2020, with employers of all sizes increasingly embracing the model. The flexibility and cost-control potential are driving its widespread appeal, with a 34% growth in adoption among large employers from 2024 to 2025.
Oscar Health recently highlighted ICHRA as a central component of its long-term strategy to create a more competitive healthcare market. In their latest earnings call, Oscar’s CEO emphasized that, while the individual market is going through a reset, it remains resilient. The company views ICHRA as a key driver of a growing and stable risk pool, with significant long-term growth potential. To further diversify their business and strengthen ICHRA, Oscar has been making strategic moves, including acquiring assets like a direct enrollment technology platform and launching an ICHRA product with Hy-Vee.
Centene is also making strides in the ICHRA space. Earlier this year, they hired their first ICHRA president, who in an interview, he shared the company’s strategy for tapping into this growing market. Centene views ICHRA as a core component of its growth strategy, aiming to offer more personalized and flexible healthcare solutions to its members.
Although the ICHRA market is still in its early stages, the support of innovative players indicates that ICHRA has the potential to reshape how employers and employees navigate healthcare coverage. In this interview with Amanda, we take a closer look at ICHRA’s potential and the challenges that need to be addressed for it to reach its full scale. From its impact on cost management to its ability to enhance the employee experience, this conversation highlights why ICHRA is poised to be a central piece of the future of healthcare.
Questions
Q2: When employers evaluate ICHRA, how often are they comparing actuarial value and network quality versus just looking at premium costs?
Interview
Q: How do you distinguish between cost savings and cost shifting in the context of ICHRAs?
It’s a great but admittedly loaded question—because in the near term, it’s both. ICHRAs are fundamentally a cost management tool, but the degree to which they lead to savings versus cost shifting depends on the employer’s starting point. For some—particularly those exiting costly fully insured markets or offering benefits for the first time—ICHRA can provide a more affordable and predictable way to offer coverage. For others with richer group plans, savings may only be realized by transferring more cost and complexity to employees. In both cases, it may appear cost-effective for the employer, but whether that reflects true value or simply burden-shifting depends on how the benefit is designed and supported.
Over time, ICHRA’s potential to drive system-wide savings remains to be seen, and importantly, hinges on the evolution of the individual market. That means more affordable, competitive plan options; innovation in care delivery and benefit design; strong decision support for employees; and regulations that enable a sustainable individual market.
Q: When employers evaluate ICHRA, how often are they comparing actuarial value and network quality versus just looking at premium costs?
Ideally, employers evaluating ICHRA would always consider actuarial value and network quality alongside premiums—but in practice, it depends. Smaller employers often focus primarily on affordability, while larger employers are more likely to want apples-to-apples comparisons to minimize disruption. But even when those comparisons are desired, they’re not always feasible—many individual market plans today aren’t designed with group-to-individual transitions in mind. This is a key area where platforms are investing, building tools to surface AV, network breadth, and provider match. But for ICHRA to truly deliver on its promise—a more affordable, flexible model that doesn’t sacrifice value or experience—carrier product design needs to evolve to better reflects the needs of employers and employees coming off group coverage.
Q: Which types of employers do you believe are the best fit for ICHRA?
Ultimately, the best-fit employers for ICHRA are those whose priorities align with what the model offers—cost predictability, administrative simplicity, and flexibility. Early industry expectations focused on small employers priced out of group and large employers looking to exit group coverage, and while those segments remain relevant, real-world adoption (while still small relative to other commercial lines) has broadened. We’re seeing strong interest from multi-state or distributed employers, small and mid-sized groups seeking more budget control, and larger employers piloting ICHRA for specific roles like part-time or remote workers. Even public-sector groups like school districts are starting to explore the model—highlighting that fit depends less on size or industry and more on what the employer is solving for.
Q: Where have you seen the ICHRA model fall short or fail to deliver on its value proposition?
I’m sure there are many answers to this, but where I’ve seen it fall short is when there’s a mismatch between the employer and the platform partner. Platforms play a central role in the ICHRA experience—for both employers and employees—but they’re not one-size-fits-all. Some are built for small groups and first-time benefit offerings, while others are designed for scale or more complex configurations. When expectations aren’t aligned—whether around billing, compliance, or employee support—it can lead to real breakdowns like missed payments, subsidy eligibility issues, or a frustrating employee experience. It’s not that platforms are failing—it’s that they each specialize in different things. To make ICHRA work, it’s critical that employers, brokers, carriers, and platforms are aligned on roles and responsibilities—and that clear processes are in place to troubleshoot issues and coordinate across partners when something goes wrong. Execution and coordination matter just as much as strategy.
Q: Describe the employee experience under ICHRA, focusing on positives and common pitfalls. How are employees being supported during the plan selection and enrollment process? Do you believe employees are adequately equipped to navigate the marketplace options presented under ICHRA?
A positive ICHRA experience is one where employees feel informed, supported, and in control. They understand what ICHRA is, how their employer contribution works, the difference between the platform and the carrier, and how to compare and choose plans. The experience improves further when employers also support out-of-pocket costs, not just premiums—helping employees manage total cost of care.
Where it tends to fall short is in the transition and execution. Even seasoned professionals can struggle with plan selection—I’ve spent my career in health insurance and still find group plan decisions for my family challenging. That complexity only increases when employees are navigating the individual market for the first time, especially if communication is unclear, accumulators reset mid-year, or a platform switch creates billing or coverage disruptions.
Many platforms offer guided plan selection and enrollment support, and we’re starting to see more emerging capabilities like comparisons to a prior group plan and claims-based plan recommendations. But even with these tools, a great ICHRA experience depends on thoughtful design, clear communication, and strong coordination across employers, brokers, carriers, and platforms.
Q: How do network limitations or inaccuracies in provider directories affect ICHRA adoption?
Provider directory issues are industry-wide, but they’re especially problematic in ICHRA, where employees are selecting their own plans. Inaccurate or incomplete data can quickly erode trust in the model. Fortunately, there’s growing momentum behind national directory efforts and AI-driven improvements, which will hopefully lead to a better experience over time.
More broadly, there’s a pervasive perception that individual market networks are weaker than group, which can create hesitation among employers and employees. In reality, I’ve heard mixed feedback—in some cases, the networks are quite comparable, while in others, the differences are more pronounced. But overall, I think the industry recognizes that network strength and transparency will need to evolve if ICHRA is going to continue gaining traction—especially with larger, more complex employers.
Q: Are there specific populations—such as families or individuals with chronic conditions—that face more challenges under ICHRA arrangements?
Yes. Families, individuals with chronic conditions, and older employees often face more complexity under ICHRA. These groups are more sensitive to premium costs, provider or formulary disruptions, and the risk of high out-of-pocket exposure—especially if the contribution strategy isn’t aligned to their needs. That’s why it’s so important to choose the right platform partner and work with the broker and platform to design a thoughtful contribution model that minimizes disruption. It’s also a reminder that ICHRA isn’t a one-size-fits-all solution. Success depends on the makeup of the workforce, the local market, and how well the model is executed.
Q: How do you view the role of ICHRA administrators today? Are they solving key problems or adding complexity?
ICHRA itself is an avenue employers can take to solve longstanding challenges—offering cost control, flexibility, and individual choice. But it’s also inherently different from traditional group coverage, and that difference creates new complexity.
Administrators play a critical role in helping employers, employees, and carriers navigate this new model—handling compliance, enrollment, reimbursement, and helping the benefit still feel like a “group”. In fact, they are the only thing today that maintains the group admin ease and cohesion while allowing individual employees to choose different carriers and plans. In the near term, they do introduce complexity, but they’re also accelerating the kinds of interoperability, consumer choice, and data exchange that the industry needs to evolve.
Q: Do you believe admin fees for ICHRA platforms are sustainable as the market matures?
No, and I think most industry stakeholders—including platforms—know this. It’s a very crowded space, and as automation improves, the market matures, employers become more sophisticated buyers, and consolidation takes hold, admin fees will compress and eventually stabilize.
To stay competitive, platforms will need to evolve—moving beyond basic administration to deliver real value through employee guidance, compliance support, data insights, and ultimately helping drive outcomes and affordability. We’re already seeing signs of this evolution, with some platforms expanding into areas like curated marketplaces, plan navigation tools, supplemental benefit integration, and broker enablement.
Not all platforms will make that leap, but those that do will be best positioned to thrive as the market settles into a more scalable, sustainable model.
Q: What would need to change for ICHRA to scale more broadly among large, self-funded employers?
I think the biggest thing that needs to change is confidence in the individual market. While some self-funded employers are already exploring ICHRA or moving certain populations, most are holding back—and understandably so—given the uncertainty around how the market will evolve, especially with policies like the OBBB. For ICHRA to scale, employers need to see a sustainable, affordable, high-quality individual market, backed by clearer regulatory footing and a model that meets expectations around employee experience, data, and outcomes.
Q: What is the most common misconception about ICHRA in the market today?
Depends on who you ask, but the one I hear most often is that ICHRA is just private exchanges 2.0. On the surface, the comparison makes sense—choice, defined contribution, individual decision-making—but it misses a key distinction: private exchanges were still tied to group plans, while ICHRA is built on the individual market. That’s a much more meaningful shift. Again, it’s not perfect—it doesn’t yet solve for removing cost from the system—but it’s a step in the direction healthcare needs to go
Q: Where do you see the ICHRA market headed in the next 3 to 5 years?
This is the big question, and I get it a lot. It’s still early days. ICHRA will continue to grow, but it won’t be an overnight boom. The market is working through operational and regulatory complexities, and with the ACA potentially resetting next year, growth could be somewhat uneven. That said, rising affordability pressures aren't going away, and ICHRA is one of the few tools available today that gives employers—especially smaller or more distributed ones—a way to continue offering coverage.
As adoption increases, we’ll likely see platforms evolve to deliver a more integrated, employee-friendly experience, and carriers will need to treat ICHRA as a strategic channel, not just an edge case. If the individual market continues to strengthen, ICHRA could become a core part of the benefits mix, not just an alternative for niche segments.
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