Exploring the Future of ICHRAs with Mark Mixer & Jordan Ledford

In this episode of the Insurtech Building Blocs podcast, host Cory Schmidt welcomes Mark Mixer and Jordan Ledford of HRASimple. They dive deep into the world of Individual Coverage Health Reimbursement Arrangements (ICHRAs) and discuss the evolution of HRAs, the market drivers for ICHRAs, and the complexities involved in transitioning to this new model of employee benefits. Their conversation highlights the importance of education, technology, and the future potential of ICHRAs in the insurance landscape.

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Chapters

• 0:00 Introduction to ICHRAs and HRAs
• 3:55 Understanding the HRA Council and Its Impact
• 5:52 The Evolution of HRAs and ICHRAs
• 8:31 Cost Considerations Driving ICHRA Adoption
• 11:59 Market Variability and ICHRA Implementation Challenges
• 15:47 Modeling Costs and Employee Impact in ICHRAs
• 20:03 The Role of Technology in Employee Benefits
• 24:05 Navigating Individual Choices in Employee Benefits
• 25:57 The Employee Journey with ICHRA
• 27:21 Broker Dynamics in the ICHRA Landscape
• 29:04 The Future of ICHRA and Market Trends
• 34:15 Resources for Brokers on ICHRA Implementation

Transcript

0:03

Hello everyone and welcome back to another episode of the InsureTech Building Blocks podcast. I'm Corey Schmidt, your host, and we are doing a deep dive into trends shaping the insurance industry. Specifically today, we're going to explore health reimbursement arrangements or HRAs with a special focus on ICHRAs. There's been a lot of talk about ICHRAs in the market and I'm uh joined by a couple of folks who know a lot about this today. So excited to dig in. uh Really, before we dig in, ICHRAs, if you're not aware, they allow businesses to have any size to reimburse employees tax-free for their health insurance premiums and medical expenses. So basically a shift from traditional employer benefits more to something that looks a little bit more like individual choice, which we've heard many employees say they would like more individual choice of their benefits. And so I'm really excited to be joined today by Mark Mixer and Jordan Ledford from HRA Simple. Thanks for joining the podcast guys Thank you, Corey. It's good to be here. Thank you. All right, well, let's dig in. Before we get maybe started on my uh line of questions and things that I'm curious about and helping you guys fill in gaps in my own mind, let's start with a little bit of background from each of you, what you do at HRI Simple and also Mark, think involved in the HRI Council as well. So if you don't mind giving the audience a quick background, that would be wonderful. Mark, let's start with you. go ahead, you start. So Jordan Ledford with Atria Symbol. I am the sales executive, so I'm on the front lines working closely with brokers and employers just on education, but also when they have specific requests on quotes, proposals, questions about Acra, I'm talking with them. So I'm the odd guy out here uh industry-wise. I wear four different hats. I'm actually a health plan CEO. So that's what I've been doing for the last four decades is running a health plan. We are a small regional player in Georgia and Tennessee, and most of our business is in the individual market. So we know that market well. And then I'm an employer. We got about 250 employees. And then I put my employees into an ICRA. So I'm an employer that has experienced an ICRA live and in person, and I've been on one. And we've been doing that for three years. And then when Icarus first came around in January of 2020, we wrote one of the first and largest employers in the country. And that is what, not by design, but that's what got us into the administration space, was that employer said, all right, you sold me on this idea. Now you administer it. And we said, So we had to build out an entire administrative platform. Once we did that for that large employer, we realized we could actually market this across the country and apply it to any size employer. So that's sort of our history. Because I got put in the spotlight early on back in January of 20, that got the attention of the Department of Treasury and CMS and the Department of Labor. And so I began to collaborate with them along with others that were pioneers in this field. And as we got to know each other, those other pioneers, we decided, you know, it'd be nice if we had a not-for-profit entity and we co-founded the HRA Council, which now, four years later, we're the nation's leading advocate for legislative policy on ICRA. uh House Ways and Means Congress on both sides come to us for data and understanding of ICRA. And then we're on our fourth year of data reporting. which just came out about three weeks ago. And that now we've got, I think, 55 participants representing all the major administrators in the country and many of the large individual players in the insurance market. know, Centene and Better, many of the Blues, et cetera. So long answer to your question, sorry. No, it's very helpful. In fact, I was actually looking over the HRI HRI council report, Mark, prior to this podcast. I feel like there's not a lot of strong data around the usage of HRAs and specifically ICRAs. And I felt like the work that's been done by the HRI council was maybe the most, uh you know, illuminating data set that I could find. Yeah, there's been some others, but I think we would be very quick as the council to say we are not the collector of all data out there, but we feel like we're the only ones that have got an aggregated data collection of who has probably got the most volume in the market. And we tend to be very Switzerland-oriented in our education. We're about educating. We're not about trying to promote uh one administrator over the other, et cetera. uh Remember, ICRA is still in its infancy. I'll give you a comparative. ERISA, which governs any welfare plan that an employer might have, that's been around 50 years, 52 years now, actually. Well, ICRA is brand new. So you've got millions of pages on how to understand ERISA regulation. You've got. virtually nothing on how to understand ICRA administration. So it's a little bit of the Wild West and brokers need to be careful of that in who they're listening to around how you best comply with ERISA governed ICRAs, which ICRAs are governed by ERISA. So you got to be careful of that. Yeah, interesting. So let's maybe take a little bit of a step back and make sure that folks that are tuning in that aren't familiar with HRAs or specifically ICRAs, let's give them a little bit of lay of the land. what are HRAs specifically? Why are they in the spotlight? And then maybe what's an ICRA as it relates to an HRA specifically? That's a great question. If you look back, the jet tour history is this. They started out as Merps, which were medical reimbursement uh plans way back in the 60s. And some of your white collar firms would use them to supplement the health insurance offering that they would do for their executives or maybe their management team. And then as they got established uh in the uh early 2000s, is when the true form of health reimbursement arrangements kind of came into being and began to get regulated. And they were exclusively used to reimburse for medical expenses that a traditional plan didn't cover, uh as well as a laundry list of other things like wheelchairs or over-the-counter drugs, et cetera. uh For years, it was forbidden by law that you could reimburse out of that employer's money premiums. for insurance. And then that changed under the Obama administration in 2016. But the Obama administration only enabled small employers who had never offered coverage before to kind of combine employer coverage and then tax credits. And they would get kind of uh an easy on-ramp to offering benefits. Those were called Q-SERAs, right, qualified small employer HRAs. Then under the Trump administration in 2019, he expanded that. They wrote rules in the first kind of open book. Any size employer could now take advantage of reimbursing for health insurance premiums. And when that happened beginning January of 2020 is when things really began to take off. So HRAs aren't just individual HRAs. You can have specific HRAs for limited benefits, you can have them for other medical benefits. They don't always have to be applied only to individual coverage, but right now the hot topic is ICRA, right? Right. Yeah. And also increasing the amount of alphabet soup that I have to keep straight in my brain, which is much appreciated. So. and don't get too used to it because we're working with Congress right now, as a matter of fact, on a new healthcare bill in which they'll rename it Choice. Instead of ICRA, it'll be called Choice. So you've got to rebrand everything. Okay, well maybe I'll remember that one a little bit better than I will Ickra. It's the worst acronym ever by the federal government, I will agree. I would agree with that. So ah Jordan, I'm kind of curious, you obviously work with a lot of employer groups in terms of implementing these plans. What's the primary driver that you're hearing from the market, why employers are looking at this uh model? It's all centered around cost. That's usually the origination of at least interest in ICCRO. m They get a big renewal on their group plan. um Then once you get into the conversation, they start to uncover other things that ICCRO can serve like employee freedom and employee choice, going back to the acronym. um But it usually is the driving interest is all around cost. Okay, yeah. to seek a better option uh for something that they can't afford. Right. noticed on the, think it was the 24 uh HRA council report. said that small groups, think like 52 % of them, the main concern was cost control and plan customization as the primary drivers. And frankly, I was surprised the number was that low. Like I figured that would be like 90 plus percent, you know, uh as a small business owner, like one of the my least favorite times of the year is when we go through open enrollment and we're waiting for that, you know, that that carrier renewal, right, to see how bad it's going to be this year. you know, in a year where I think I read that like healthcare trend is already at like 11% and the carriers are facing, you know, increased pressure on margins. I have to imagine there's a lot of tailwinds for ICHRA specifically. Is that something that you're seeing play out? em Absolutely. I don't think there's any question about that. The problem comes when, if I'm a broker sitting in Missouri, the answer to how hot is ICRA in that market versus Ohio versus Nebraska versus California, et cetera. Every market's a little different, and it depends on how those state departments of insurance have regulated, believe it or not, how they've regulated stop-loss. Because in a fully insured small employers, most states define that as 50 and fewer. Everybody's abandoning the fully insured market. Well, where are they going? Right? They're either going, you're not offering benefits at all, which means they're just pushing their employees to the individual market. Or they're moving to level funded, which is a 180 degree difference than fully insured, where they were. And many small employers don't understand that. In some states, they've regulated stop loss to where small, micro-sized employers can't buy level funding, can't buy stop loss below 25 employees, for example. So in those states, you've got to look for employers that are high utilizers, but still want to offer benefits to recruit and retain talented employees. I that's the only reason you offer benefits to begin with. So the answer to where, where did I look? uh It depends on the state, number one, how different the group market premiums are to the individual premiums. 38, well, I'm gonna guess around 30 out of 50 states individual premiums are lower, but you have 20 states where it's inverted. That doesn't mean that ICRA isn't a board that can be deployed. It just means you gotta search harder for a prospect that fits the right mold. High utilizers, people in multiple states, you know, they're tired of the annual angst over renewal. You know, you got employees complaining that my employer always picks a plan, but it's still too expensive for me. And I hate the carrier they picked or the network. mean, all of those still apply. Yeah, interesting. And I did wonder like how in the States, because we see the same thing with our, uh, we have a product called quote plus that helps solve for like level funded, uh, funding arrangements and, and, know, getting, getting quotes for those products. And it feels like the States where that applies is what you mentioned, Mark, where there's a dislocation from like the fully insured market where it's gotten so expensive or the guaranteed issue market to like what you can get if you're willing to go through underwriting. Do you think that over time the states where ICRA plays, like do you think the individual premiums will start to increase to be more on par with like the group premiums because essentially we're shifting risk over to that market or is that not a concern? Oh no, it's a valid concern, particularly for next year. So remember when I gave you my history, I've spent 40 years as a health plan CEO. So I will tell you that rates for next year are going to be well into double digits of, you you're talking probably a minimum of anywhere from 12 to 15 % next year for individual premiums, all the way up to 30, 40%. All right, because of the changes that the Trump administration has made, trying to tighten the guardrails around rogue agents, people writing business, uh as well as increased medical costs. uh The United Health Care uh Group CEO just the other day on an investor call said, we've had a decline in the number of fully insured groups that we've had. And they write more than anybody in the entire country, right? So we should listen to what, when they say these things. And then they said, we expected trend to be 10%, it's not, it's going to be more above 11, right? And then we expect a migration at a fully insured, you know, small group into level funded. And then one of the main drivers of that is that, and that is a dangerous move for small employers. So they're about to get hit kind of double whammy, but let's go more simple. If my base, for in Georgia for example, my base for individuals here in small group is here, well if medical trend is 11, they just move up together. I'm still going to be well below. Group would have to flatten at a traditional 7%, let's say. An individual would have to rise double digit for number of years before they would catch up in a lot of states. So historically, individual plans since 2017 have tracked CPI. Group has been doubled CPI. So next year is going to be an anomaly, but it'll homogenize some of the rates where it's close. But there's probably 17 states where even a 15 % rate will still make individual cheaper than group. Yeah, it sounds like it would take some amount of time for those to come closer together, probably a long amount of time, like you said, with some significant changes. Yeah. and it was, you know, let's be transparent about it. 2014 to 2017 rates were, I mean, they were all over the board. Nobody could figure out how to make money in it. Then 2017, we all figured it out, right? And then rates have been, you know, it's been a slow burn up since then. Yeah, interesting. So what's the, when you guys think about, you know, going into an employer group, having the conversation about ICRA, what are kind of the decision points that the employer is going through? What are they evaluating as it relates to this? Like, obviously, you know, the fully insured market is, you know, you're getting quotes from the carriers. It's a, it's a, you know, a premium across your full risk of your employer, employee base. What's the process look like to get, to get onto an ICRA? style benefit plan, So you have to remember employers, especially brokers are working with, are locked into a group world. And so to go into an ICHRA, now they have to translate their knowledge and their verbiage into the individual market. And so you're having conversations about funding, but you're also having conversations about plan design and you're having to consider what plan offerings the employees are going to find and what that looks like. It's different in that world compared to the group world. you know, going back to what I said earlier, first and foremost, they're concerned about costs and what that looks for them, but they also have to, as an employer, have to translate what they're used to to their employees as well. And so we're having all these conversations kind of centered around what's different compared to the group world, what they're used to. And, but, what in good ways and bad ways, right? here's what it's going to look like. Not necessarily bad, um but it's different. And so just trying to wrap their head around that, um you know, is kind of where most of the conversations start. imagine there's a fair amount of like modeling that's required then as it relates to understanding like the Mark's chuckling, the plans that like, like, what does, what does this plan that I have on my, with my employer group look like on the individual market? What do those rates look like? Like, it sounds like fairly complicated, especially like I think about our own business where we have employees all over the country, right? And they would have different options available to them in the individual market. Like how How hard is it to like model out the actual effect on costs? Almost impossible. When we're putting proposal together, for instance, we have to make a lot of assumptions outside of participation, outside of what employees are going to choose as far as plans and basing the funding off a certain model as well. So it's complicated um and we do our best, but you have to make a lot of assumptions. uh It's really, really hard to give uh a true, accurate, perfect picture of what it's going to look like for the employer because I don't know that there's one way to do that when you consider everything. think one of the things that we did well early on and we've held to this kind of as our true north is we're very transparent about what assumptions we've made. We get buy-in from the employer and then we We actually model it all the way down to how this decision would impact every single employee by name. Because the last thing you want to do, uh we wrote a medical facility. when we did the modeling, it was the chief nursing officer who was going to get hurt. And we made HR aware of that before. They made it said, I can't fix this, in other words, in a NICRA. I can't adjust it so that she doesn't get hurt. financially, you have to adjust that on payroll. Well, the fact that we had that conversation early on, they were able to mitigate it by fixing it by a payroll. And the other several hundred employees benefited then from moving to an Ingram. But if you don't know that going on in, you're going to get sideswiped and the employer's not going to be very happy that that wasn't told early on. That, I think, has probably been the one piece. You've got safe harbors that we deploy where, know, if you fund it this, as long as you fund it at this level, you don't have to worry about compliance and those sorts of things. Once you get, once you understand those and you automate them, it's a little easier to generate, you know, quote early days. To do a quote for a hundred people, it would take us two weeks. You know, because we'd say, go, how do you do this? And how do you get to this number? Where do you get the rates from? It'd be fine if everybody were in one spot and then you get the one guy that's in Massachusetts and they're in a state-based exchange and you have no data. What do you do with that one guy? Now we've worked through all those cakes. Yeah, I've seen, I've noticed an influx in the number of like quoting and administration platforms in this space. And obviously there's been a, I think a tremendous level of investment, you know, even in like technology startups. uh are you guys seeing on the technology front and like, what is the role and how important is technology to solve for that complexity that you're referring to? You want to start on that one? I have my own thoughts. I live in more of the strategic world. And then as the past chairman and now I'm chair emeritus at the HRA council, I get to see kind of this at a 50,000 foot view. But it might be better to start from the ground. What are brokers facing with this? There's like 47 administrators out there now that are at least known. There's probably more to that. So I think technology certainly plays a role uh in trying to bring all of it into one place, right? So plans for the shopping for employees, funding, uh employer uh visibility, so they can kind of manage what's going on between their employees. So it certainly plays a role. uh It varies, of course. mean, there's tons of administrators. Every administrator's technology platform is a little different. But I think the question to ask is for each of those administrators, what are they trying to accomplish with that technology? Because there's certainly some technology that it's not maybe well laid out and can make the process a lot more complicated and convoluted for the employees and for the employer. You think about where some of these tech companies had their genesis, right? You've got disruptors that were tech people that saw an opportunity and they've entered the insurance world and then they realize, crap, I got to figure out how the insurance world works, right? Because IKRA is literally nothing more than accounting. That's really all it is at its core, right? But if you want to create a great user experience for not only the employer but the employees, you've got to create an ecosystem that enables them to see everything, all of their choices. How do I migrate? In my county here, there's 96 plans I can choose from. That's too many. do I use technology to narrow that down? And if I'm a tech company, and brokers need to pay attention to this, what you'll hear from the tech type people are, Well, coverage is coverage is coverage. They bought a gold plan, who cares where they bought it from? But as brokers, okay, which I've been one for 50 years, right, as well, I know that it is an equivalent, that a bronze plan from this carrier is much different than a bronze plan from this carrier. And that's the difference. If I were back on the street today trying to make a living as a broker, uh I'd look for an in-bicker administrator that came out of the insurance world and understood that technology makes life simpler, but you have to understand the insurance side of it. If you lose sight of that, it's just going to be a transaction-based event. It doesn't matter what they bought. I just got them coverage, so you should be happy. But that's not going to experience, for the beneficiary, it's not going be a good experience. if they didn't pick a plan that they understood. And that's really the broker's role. Yeah. Yeah. I imagine a fair amount. You guys even referenced this earlier. A fair amount of this is like, you know, everybody wants that individual choice. They want that control, but like once, once, you know, you push that down to the individual employee level, I imagine there's just a lot of like questions, confusion. What does this look like? How does this work? How do I, how do I wade through the 96 options and select the one that actually resembles the plan that I have today or the plan that I want? What, what does this look like? So let's you know, let's take an employer group with 100 employees and they're going to go onto an IKRA platform. What does it logistically look like to get the hundred employees signed up for individual benefits? Like how does that, I can't imagine like the complexity of how that actually works, especially if they're distributed in different markets where maybe the broker that's helping them with the IKRA platform doesn't even have a license to sell insurance and in Georgia, right? So how, like, how does this work? I will tell you, so this is our experience, right, literally, now we're in our fifth year, moving into our sixth year of this next year. This is exactly what the member or the employee journey looks like. Before we even get there, somehow they've been told, next year we're moving to this thing called a NIC or everybody, and all the employees do this. They're taking away our benefits. Every year it just gets worse and worse and worse. And literally, and then we go, we're gonna have people you know, either it's online webinars or on site. And they walk in to either with that attitude. This is horrible. All right? And then we go, well, let's unpack what's happening. And then as we unpack it, they begin to do. Now what? Now say that again. And they go, oh, OK. So now I'm beginning to understand it. So education is key to this, right? Not only to the employer, but with the employee. And then they realize, oh, you mean I used to have a payroll deduction and now because of the pricing and the individual, I don't have a payroll deduction anymore, so I just took a raise and pay. But then I get to pick whatever plan is best for my family. That's great, except I don't know how to pick a plan. Well, we can help you with that. And they walk out, okay, not everyone, let's be fair, right? But the vast majority, they start here and they walk out and say, this is great. And that's evidence now in our data reporting at the HRA Council that renewal or stickability of an ICRA, we have yet, to my knowledge, of all of our accounts, we've never had an account say, yeah, this ICRA thing ain't for me after the first year they've gone back to group. We've had firms that get bought out and they get moved back into group at the bigger company. But we've had nobody, to my knowledge, that said, we hate this ICRA thing. We're going back to traditional company. But it's that jump in that first year that they gotta be bold enough to make the jump. Once they do, it's usually a fairly positive member experience. we're involved, he and I are involved in the actual enrollment of people. We're in the trenches with everybody else trying to make that happen. So typically those employees then are working directly with that group broker to try to navigate how to get into the plan for them. two models out there, Corey, among administrators, those where the broker says, this is almost always the first question we get. Do you require that you're the agent of record, or can I be the agent of record? And that's a fair question. We require we're the agent of record, because then we can own the whole ecosystem. If you want to be the agent of record, then you have to find an administrator that allows for that. But remember that now you've got, when the employees have a problem, administrator can't help because when they call Ambetter or Cigna, you're going to say, we don't know who you are, you're not the agent, click. So you're going to get all those calls. So you've got to work with an administrator that allows the broker to remain as the strategic advisor, right? It doesn't have to handle all the machinations of an ICHRA, you know, because you still have all the mods, ads, terms, people come, people go, you know, new hires. termination centers. When I think about our customers, it's interesting to bring that up. Like I know how protective they are of their book of business. And so I think I have heard that in some of the platforms, the technology platforms that are out there, like they're, they're taking over broker of record. And actually, I think it reminds me a little bit of like what happened with Zenefits so many years ago. And I'm just curious, like, it sounds like you guys are seeing the same thing. You definitely have the awareness of people wanting to retain that. to, if you remember this history, what did, did Zenevitz becomes, became Peoplekeep, right, that now is owned by Remodel Health, which is a dominant ICCRA administrator. They know where the money is. The money's in the commissions, right? I mean, just, you have to unpack it in that, in that regard. I don't mean to be crass about it, but If all you're going to try and do is make money as a technology firm in a transaction-based event, which is all hickorism, a charge of per employee per month fee, well then, you you better have a lot of value for whatever it is you're charging. Because the other 48 administrators out there are going to come in and say, well, we can do it for cheaper. And if the response is, well, we'll match the price, well, it's just a race to the bottom. So all of the margin is in the insurance product. That's why if you're a voluntary product agent, right, you're an Aflac, Colonial, Mutual, all those guys, ICRA is a godsend for you because it actually creates the savings that you can then use to pay for your product. You don't have to know anything about ICRA to do that. Give it to an administrator. They'll do the querying, they'll administer it, they'll install it, they'll handle it. You just go sell your pet insurance, your accident insurance, your bridge insurance, all of that, right? Same thing for other advisors. And this is where brokers get painted into a corner, is they think, well, we're the sole influencer for that employer and what they do with group insurance. Not anymore. Now have accountants talking to their employers about, you realize how much money you might be able to save? You have attorneys talking with their employer clients. You have P &C agents that are saying, hey, I got to figure out a way to cover my increase on my P &C cover. Have you guys looked at this ICRA thing? Because I just had another client that just saved 20%. And if you are not prepared to have that conversation, you're going to get painted out of the picture. So it isn't that you will lose a case to ICRA. It's that they're listening now to other advisors who have morphed into being better strategic conversationalists. Related to that, are you guys seeing any influx of like what like traditional individual insurance brokers getting into this because they feel more comfortable working with groups or is it typically still staying on the employer side of the house? Do you see that at all? I think it certainly bridges the gap. I don't know that there's been this massive increase of individual brokers flooding to group world or to employers, but it definitely bridges the gap for them and gives them a little more reach. So it's there. I don't know that it's rapid. Yeah. The tendency is You tend to migrate into one or the other. oh If I'm big in the individual market, I may know about group, but I'm really not an expert in group. I'm an expert in individual. Well, now I got to figure out how do I understand the group implication because this, remember, ICRA is an ERISA-governed health plan. So you got to understand the compliance side. If I'm a group person, I get all that. I get ICRA, I get ERISA, understand. m how that's still a group plan, right? But I don't have any idea how the individual market works, and it works completely different than a group plan does, right? So both sides have got an education deficit that they have to kind of learn about. The best are those particularly kind of small town, mom and pop agencies that live in both worlds and understand both really well. They're at the spear. of being able to accommodate those employers right now. Others have to bring that expertise to the table. It also feels like there may be a long-term opportunity for those individual insurance brokers to partner in some way with these brokers that are implementing the ICHRAs in terms of helping the individuals actually get through the individual plan selection and enrollment process. Well, think about it. We've, you know, as brokers particularly, and I come out of the group side, I was looking for, you you always want to find the one employer that brought you 10,000 employees because that way you only have one account, right? I just had to keep that one employer happy. And then carriers deal with this all the time. go, well, no, I'd rather have all small groups. And every carrier actor goes, no, you don't. I'd much rather have five. 1,000 man groups than I would 500 10-man groups, right? Because what? Because of volume. Well, now you're in the same position. You move someone from a group to an ICRA, you just moved them to one employer client. So now you still got the same employer client, but now got 50 employees, you got to go find insurance for it. And that might be different for every single one of them in different states. So the complexity just gets amplified, you know, exponentially in that. You got to be ready for that. and it sounds like they would need a really strong agency management platform, Mark, for managing that business. I don't even have just one license with the guys. I have two, right? Because you were the right solution to be able to handle both sides of that. I have an agency, right? We're one of the largest agencies in Georgia. And then the ICRA side, I had to manage from a CRM perspective, not so much as a policyholder. And your platform saw those perfectly for us. It was a great, great find. And I wouldn't be in pain for that. I really actually, I'm the one who found you and said, this is a good solution. Love it. Yeah. Our roots are actually in the space where you're doing both individual and group. And I think that's pretty unique amongst, you know, the players in our space. So ah maybe just as we kind of like wrap things up, I want to hear from you guys about, you know, two more things. One is like, we've talked a lot about the complexity of learning IKRA, implementing IKRA. It doesn't sound very simple. You know, it's definitely something, well, I guess HRA is simple. Maybe you guys have figured out how to make it simple. I don't know, but. laugh about that. But I'm curious, where should brokers turn to to look for more information about, know, ICHRA specifically if they're interested in potentially getting those options in front of their employer groups as they renew? What's your recommendation for how to get ramped up on this? This is the equivalent of saying, hey, I don't feel well. My side hurts, so I'll go ask Dr. Google. And you'll find a million resources. It's similar to that. I would encourage you to do this. NAIDBET, certainly, I helped co-author the three-hour course at NAIDBET for ICRA certification. So it's a neutral place to where you can be assured your education is in creating best practice, right? It's not, I'm not promoting even my own administration company there. HR at Council, we just finished uh a three hour course there along with six one hour courses that you now have access to. Those cost money. uh You've got other ICRA firms and carriers, right, that will put on webinars around ICRA. I would always look at an administrator that's doing the education in light of, are you telling me what's best practice or are you telling me what you want me to hear so that I'll pick your administrator? Right? I think that's the difference and that's hard to decipher. uh I wouldn't rely on any one source. I'll give you an anecdotal picture of this. One of the biggest problems with ICRA You have to notify the employees 90 days before the plan starts, right? Well, you don't even get your renewal 60 days before, so it's a real headache. And I was talking to one major administrator on the council, and we brought that up. We were gonna bring it up to the Senator from Oklahoma on house ways of means. And he goes, all right, we just tell our employees don't worry about And I was in shock. And I said, so I'll just remind you that it is crystal clear in the governance. And it's up to $1,100 per day, per participant. Fine. If you don't do it. If you get audited, and it was a gross fight. I don't know that I want to be the advisor. And he goes, yeah. goes, because most of our accounts are small. Nobody's going to get audited. Well, that's a problem. Because now, if I'm taking that advice and I go carry that forward, If I'm not matching those compliance regulations or addressing them with the client, I'm really at risk. So you want somebody that comes alongside you and helps you navigate through all of those waters. You've got to find somebody you trust. It doesn't have to be only one, but I've picked one or two that you really like and then learn the way they do it. They'll be super easy. Yeah, great advice. And I think, you know, I always reinforce NABIP. I feel like they do a great job of being like you mentioned earlier, Switzerland mark in this, you know, they're trying to educate and empower brokers to be more successful and bring better products and better service to their, to their ultimate customers, which I think is an admirable mission that they have. ah Maybe, maybe to wrap things up, you know, you mentioned that, you know, at times I feel like I've heard that employer groups kind of have to look at this one year and then maybe look at adopting at the following year just because of what you mentioned around notice periods and just like trying to wrap your arms around this. Like it feels like if you're going through a renewal, that's not the right time, you know, to make this kind of transition. And so I feel like the growth in this market is actually, you know, kind of like backloaded a little bit. Like I feel like there could be more growth in the market, you know, in future years as people are becoming more aware of this because you have to kind of get, get your your mind wrapped around it before you're ready to actually implement it. How do you guys see the velocity of this market picking up? I mean, I think I've seen lots of different estimates, but let's just say maybe there's like around a million people covered under ICRA plans or somewhere maybe in that neighborhood. And there's like, think 154 million on employer benefits today. Like how do you guys see the market transforming over the next couple of years? um I'm curious to hear what he's going to say. I think at the moment it's going to be steady growth, especially now that you've got the eyes of the government. Legislation um talks about that, that will extend certain um tax credits and things like that. So now that you've got that attention, I think that in two to three years you're going to begin to see some real hyper rapid growth and adoption of ICRA. um I know that might be bold to say, but I think that as more and more people learn, whether it's brokers or employers, uh it's certainly coming. I'll add a little more clarity to that. think I agree with that. I think if Congress passes the things that the House had in the original big, beautiful bill, and they allow for on market plans to be counted in where a salary reduction exists, that's the crux. If that happens, it will move the adoption of ICRA into hyper speed. We're not anywhere near hyper speed right now. We're very similar to where 401ks were back in the mid 70s. It's slugging along. Remember 401ks were never intended to replace pension plans and yet that was what happened and that's my prediction. Ten years from now, if you're listening to this now, ten years from now you'll look back and say, my god, I was around when this thing started and I think it will become the way that small employers particularly offer benefits. Large employers, they're absolutely the ones that take forever to make a decision. It's not even a one-year decision. Sometimes it's two or three. But they're under the gun as well, right? The medical cost trend rarely goes down. It almost always goes up. So they're looking for solutions as well. One thing people tend to forget is it doesn't have to be moving all your employees over. Move one class of employees and test it out. There's 10 different classes within ICRA. All right, and that's how we wrote our biggest client. The first year we only wrote one division and it went so well that literally they went, let's just put everybody on this the next year. So that's often a way to get kind of your toe wet, dip it in the water. Interesting. Yeah. I wasn't aware that you could do kind of a fractional or partial approach to, yeah, or adoption. Well, great guys. This was really insightful. I'm interested to see how this like parallel to the 401k plays out, Mark. do think like, I do think as an employee, as a business owner, think the, you know, the desire for us to drive more choice and selection down to the individual employees and not get in the middle of their health decisions as it relates to their insurance coverage, I think makes a ton of sense and it will be really interesting to see how this plays out. But this is really helpful for me to get my arms around kind of the different dynamics and you guys are doing some interesting things there at HRI Simple. Thanks for taking the time and it was a pleasure talking to you. Absolutely. Thank you, Corey. Always good to see you. Yes, thank you.