For independent financial advisors who counsel business-owner clients on total compensation, there is a structural shift underway in employer-sponsored health benefits that deserves more attention than it typically gets in wealth management circles.
Jack Hooper, CEO of Take Command, a Dallas-based platform that administers Individual Coverage Health Reimbursement Arrangements (ICHRAs) for employers, has been making that case directly to the Trump administration.
A few weeks ago he sat across from Dr. Mehmet Oz and senior officials at the Centers for Medicare & Medicaid Services (CMS) to discuss the future of what the administration now calls "CHOICE arrangements" - its rebrand of the ICHRA model that has been available to employers since 2020.
The parallel to retirement planning is one Hooper reaches for repeatedly and deliberately.
"Employers get it faster than their brokers or the insurance companies," he told InvestmentNews. "They're like, 'Oh yeah, this is what I do for retirement — we just give people money and they invest it. Why didn't we do that before?'"
The analogy is apt. Under the traditional group health insurance model, employers function as the underwriting unit for their workforce - selecting plans, absorbing cost risk, and managing annual renewals. The ICHRA model replaces that with a defined monthly contribution per employee, which the employee then uses to purchase individual coverage on the Affordable Care Act (ACA) marketplace.
The structural logic mirrors the shift from defined-benefit pensions to 401(k)s that reshaped the retirement landscape a generation ago. Employers move from absorbing open-ended liability to making a fixed, predictable contribution. Employees gain portability and choice. And a new category of administrator - Take Command among them - steps in to handle the complexity that sits between the employer's contribution and the employee's coverage decision.
According to the HRA Council's 2025–2026 annual report, more than 20,000 US businesses now offer an ICHRA, a 53 percent increase from 2025, with approximately one million Americans receiving health benefits through the model in 2026. Employer-sponsored family premiums, meanwhile, averaged approximately $26,993 in 2026 - up approximately 26 percent in five years and outpacing wages and inflation, according to the HRA Council. You may want to verify these figures against the primary HRA Council source.
For advisors with small-business and mid-market owner clients, the implications are that a business owner paying double-digit annual premium increases on a group health plan is absorbing an open-ended liability that compounds year after year.
An ICHRA converts that liability into a budget line - predictable, adjustable, and disconnected from the claims experience of individual employees.
"They don't want to be managing a health plan," Hooper said. "If they can get out of it but still take care of their employees and provide a benefit, they'll jump out right away."
The cost predictability argument is particularly resonant for owner-clients approaching succession or sale, where unpredictable benefit liabilities can complicate valuations. A defined contribution structure is cleaner to underwrite, easier to model, and more transferable to a new owner.
The critical caveat that advisors need to understand before recommending ICHRA exploration to clients: the model's quality and affordability depends entirely on a healthy ACA individual market. The administration that is currently promoting CHOICE arrangements has spent years working to weaken that same marketplace.
Hooper raised this tension directly with Dr. Oz. He also made the case for restoring Cost-Sharing Reduction (CSR) payments - federal subsidies for lower-income workers that help cover copays and deductibles, which the first Trump administration cut. Research from both sides of the aisle, he said, shows that cutting CSR payments increases the federal deficit, and restoring them now appears in Trump's own healthcare plan.
"If we can just have predictability and restore those things, we can save the federal government money and bring costs down for everybody," he said.
ICHRA works best where individual market competition is strong and plan options are robust. Before recommending the model to a client, advisors should assess the individual market quality in the geographies where their employees live, particularly for clients with geographically dispersed workforces or significant lower-wage employee populations where ACA affordability thresholds matter most.
Hooper's message to benefits brokers translating to the advisory context is instructive. He says that those who will thrive under the defined contribution model are those who think like wealth managers - helping clients set contribution levels, model costs over a three-to-five-year horizon, and adjust year by year - rather than those whose value proposition is simply running annual quotes.
"Forward-leaning brokers are starting to figure it out," he said. "Those that are stuck to 'let me just run quotes' - they're going to get run over."
For financial advisors already providing holistic planning to business-owner clients - integrating retirement plan design, executive compensation, and business succession - the ICHRA conversation is a natural extension of that work.
An advisor who can help a client model the transition from group health to defined contribution, assess the ACA market quality in their geography, and stress-test the contribution strategy over time is providing a service most benefits brokers are not yet equipped to deliver.
"I'm very convinced that at some point we'll look back in America and say it all flipped over to this model," Hooper said. "If it takes three years, five years, 10 years - I don't know - but it'll get there."
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