More than half of benefits brokers have never sold an individual coverage health reimbursement arrangement, and after a year of watching more employers try the model, fewer of them expect adoption to grow.
The TASC 2026 Broker ICHRA Survey, commissioned by Total Administrative Services Corporation, which sells ICHRA administration services, found 54% of broker respondents have still never sold an ICHRA, up from 47% in 2025. Brokers who have sold the product are reporting back on the experience: employee education and enrollment taking longer than expected, administration more labor-intensive than projected, individual-market network limitations, and cases where expected savings did not materialize. Employee confusion was the most frequently cited concern, flagged by 85% of respondents, up from 82% a year earlier.
Broker expectations for adoption growth fell 15 percentage points year over year, from 65% in 2025 to 50% in 2026. The share of brokers who fully support ICHRAs dropped from 48% to 29%. Outright opposition remained a minority position at 17%, up from 9% in 2025, but the largest shift was toward conditional support: brokers saying ICHRAs can work, but only in the right circumstances.
A separate July 2026 study by the Employee Benefit Research Institute (EBRI) and Morgan Health, a division of JPMorganChase, corroborates the pattern from the employer side. More than 80% of companies told EBRI researchers they were concerned that individual market out-of-pocket costs could be too high for some of their workers. The same study found that about three-quarters of employers said they would be more likely to adopt an ICHRA if their broker, benefits consultant, or a peer business recommended it. The EBRI-Morgan Health survey covered nearly 1,000 benefits decision-makers.
That execution friction is accumulating even as the model gains federal momentum. On September 3, the Centers for Medicare and Medicaid Services (CMS) and the Small Business Administration (SBA) formally rebranded ICHRAs as CHOICE Arrangements, short for custom health option and individual care expense, at a joint event in Indiana. The underlying structure, tax treatment, and compliance requirements are unchanged. The rebrand signals a federal commitment to expanding uptake, particularly among small employers.
The HRA Council's 2025-2026 annual data report found more than 20,000 US businesses now offer an ICHRA, a 53% increase from 2025, with covered lives surpassing 500,000. But those figures measure employer adoption, rather than broker confidence, and both surveys suggest the two are diverging.
The cost-effectiveness argument has held up better than overall sentiment. Sixty-four percent of brokers in the TASC survey still describe ICHRAs as more cost-effective than traditional group coverage, down from approximately 70% in 2025, but cost advantage alone is no longer enough to move a recommendation forward when implementation concerns remain unresolved.
An SBA and CMS joint initiative puts CHOICE Arrangements in front of small business owners who have not previously considered the model. Those employers will ask their advisers whether the product is worth exploring, and the survey data describes a broker community that has become more selective about the answer.
Christian Rosenstock, TASC's chief service offering officer, said the findings show brokers are moving past the theoretical question of whether ICHRAs work. "Brokers are looking beyond whether ICHRA works in theory," he said. "They want confidence that the right partner can make it work in practice, from implementation and enrollment to compliance, education and ongoing administration."
The TASC survey found growing broker emphasis on administrator quality as a decision factor in 2026, with enrollment support, compliance competence, and ease of administration ranking higher than in 2025. The administrator choice determines what the client experience looks like in practice - enrollment, payments, compliance handling, and the workload that lands back on the broker when things go wrong.
