BENEFITS DIGEST

CMS has paused new agent and broker registrations for the federal ACA exchanges through February 1 and canceled coverage for more than 760,000 people it says were enrolled without authorization. New brokers make up 11 percent of the field but drew 30 percent of compliance terminations for the 2026 plan year, per the agency, which has sent termination notices to more than 200 agents and brokers since January. Existing agents must re-verify their identities, and a new HHS anti-fraud group will meet regularly. A trade group for insurance professionals calls the blanket freeze "a blunt and inappropriate response" that could thin broker capacity during open enrollment. Employers that reimburse workers for individual health insurance through an ICHRA should consider whether these changes affect the brokers their employees use. Workers who buy marketplace coverage should also check their enrollment status before open enrollment.

An individual coverage health reimbursement arrangement reimburses employees for individual health insurance they buy themselves, so the employer sets its contribution in advance rather than underwriting a group plan's claims. Adoption is still concentrated among employers with fewer than 50 employees, and industry-wide enrollment is roughly one million people, but the broker channel is moving: 56 percent of brokers now recommend or implement the model, and the share that has moved at least one client onto an ICHRA has more than doubled since 2024, to 37 percent. "ICHRA is a culture change," Zorro's Ben Light says in the piece, and the education burden lands on the employer.

The fourth quarter calendar for health and welfare sponsors, in one place. October 2 brings QSEHRA and ICHRA notices and Medicare Part D subsidy applications; October 15, creditable coverage notices and extended Form 5500s; December 15, summary annual reports for extension filers; December 29, the employer share of MLR rebates within 90 days of receipt; December 31, gag clause attestations plus WHCRA and Section 1557 notices. A companion checklist covers open enrollment materials—SBCs, Michelle's Law, HIPAA notices, wellness alternative standard disclosures—and the state assessments landing this quarter, from Massachusetts payor assessments to Washington's long term care tax.

A rename, not a rulemaking: on September 3 the Small Business Administration and CMS announced that individual coverage HRAs will now go by CHOICE Arrangements, borrowing the branding from provisions of two House-passed bills that never survived final passage. Nothing structural changes—employers still reimburse individual market or Medicare coverage under the 2019 tri-agency framework—but the administration is signaling more rulemaking ahead, exploring flexibilities to boost adoption that has run well behind the original 800,000-employer projection. CMS has a new landing page for whatever comes next.

A study by EBRI and Morgan Health found employers are interested in adopting individual coverage health reimbursement accounts, but knowledge gaps and hesitation to implement remain.

are making them hesitant to move forward, according to a survey.

When a level-funded stop-loss corridor, ICHRA contribution strategy and captive loss fund can be assessed against claims data, brokers become interpreters.

The model bill establishes a tax credit for businesses that employ between 2 and 50 employees and offer an ICHRA.