If you’ve been researching alternatives to traditional fully insured coverage, two options likely keep coming up: level-funded group health plans and ICHRAs. Both have grown significantly in adoption. Both deliver more cost control and budget predictability than a conventional group plan. But before you go any further, there’s a foundational question worth sitting with: as an employer, how much responsibility are you willing to take on for your employees’ healthcare spend?
That question sits at the heart of the difference between these two models. With a level-funded plan, the employer is in the risk business. With ICHRA, the employer is not. Everything else flows from that distinction.
Choosing between them isn’t a matter of preference. It’s a matter of which model actually matches your workforce, your risk tolerance, and your operational reality. This post breaks down how each one works, where each one performs well, and what to evaluate before committing.
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In this article:Â
What is a level-fund ed group health plan?
A level-funded health plan is a hybrid funding model that functions like a self-funded plan structurally, but delivers the budget predictability most employers associate with traditional fully insured coverage.
Here’s the basic mechanism: each month, the employer pays a fixed amount to a carrier or third-party administrator (TPA). That payment is divided into three components:
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Claims fund. A portion is set aside to pay covered employee claims as they occur throughout the year.
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Stop-loss insurance. A portion covers stop-loss protection, which limits the employer’s liability if an individual claim or the group’s total claims exceed a defined threshold.
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Administrative fees. The remainder covers plan administration, network access, and related services.
At the end of the plan year, if claims came in below projections, the employer may receive a refund on unused claims funds. If claims exceeded projections, stop-loss coverage absorbs the difference. Either way, the monthly payment doesn’t change.
What’s important to understand is that the fixed monthly payment is not the same thing as fixed risk. The employer is still the one bearing financial responsibility for the workforce’s healthcare costs. Stop-loss insurance caps the exposure within a given plan year, but the employer’s claims experience follows them into every renewal conversation. A healthy workforce is an asset. A high-utilizing one is a liability.
One additional distinction worth understanding: level-funded plans are technically self-funded arrangements, which means they’re generally governed by ERISA rather than state insurance regulations. That has real implications. Employers gain more flexibility in plan design and may not be required to cover all state-mandated essential health benefits. But it also means certain state-level consumer protections don’t apply, and federal compliance obligations under ERISA, HIPAA, and the ACA require ongoing attention.
Adoption has grown substantially. According to the 2025 KFF Employer Health Benefits Survey, 37% of covered workers at small firms (10 to 199 employees) are now enrolled in level-funded plans.¹
Learn more about group health plans and critical funding strategies
Stop-loss insurance: The piece that makes it work
Stop-loss coverage is what separates level funding from straight self-funding, and it’s worth understanding how it’s structured because not all stop-loss policies are equal.
Specific stop-loss (also called individual stop-loss) kicks in when a single employee’s claims exceed a set threshold called the attachment point. If one employee faces a high-cost condition such as cancer treatment, a premature birth, or a complex surgery, specific stop-loss covers claims above that threshold for that individual.
Aggregate stop-loss covers the group as a whole. If total plan claims exceed the aggregate attachment point, typically set at a defined percentage above expected annual claims, the stop-loss carrier absorbs the excess. Both layers work together to give the employer meaningful protection from claims volatility.
The attachment points and aggregate limits vary by carrier and plan design, and they’re worth scrutinizing closely during the selection process. Plans with lower attachment points cost more in stop-loss premiums but limit the employer’s exposure more tightly. Higher attachment points mean lower premiums but more risk retained. Understanding exactly where those thresholds sit, and what happens at renewal if claims are high, is one of the most important due diligence steps in evaluating a level-funded plan.
Both layers work together to give the employer meaningful protection from the worst-case scenarios. But it’s worth being clear about what stop-loss does and doesn’t do. It protects you from catastrophic exposure within a single plan year. It does not protect you from the long-term consequences of a workforce with rising claims. Stop-loss carriers reprice at renewal based on your experience. The risk doesn’t disappear; it just gets managed.
Pros and cons of level-funded health plans
Where level-funded plans work well
The fixed monthly payment structure gives finance teams something concrete to plan around. Unlike fully insured plans, where any favorable claims experience goes back to the insurer, level-funded plans let the employer recapture savings when the workforce stays healthier than projected. For employers with a younger, healthier workforce and a favorable claims history, that upside is real.
Access to claims data is one of the most undervalued advantages. Employers receive detailed reporting on how the plan is actually being used: which conditions are driving costs, where utilization is concentrated, how prescription spending compares to projections. Over time, that information supports smarter plan design decisions and more targeted wellness initiatives. Fully insured carriers typically don’t share this data at all. For employers who want to actively manage their healthcare spend, that visibility is a meaningful tool.
Stop-loss protection addresses the biggest objection most small and mid-sized employers have to self-funding: the fear of a catastrophic claim. With both specific and aggregate coverage in place, the employer’s exposure is capped at a known level.
From an employee experience standpoint, the transition is typically low-friction. Employees interact with the plan much like a conventional group plan: same network access, same ID card, same claims process. There’s no behavioral change required on the employee side, which makes adoption easier and open enrollment simpler to communicate.
Where level-funded plans have limits
The risk story cuts both ways. Employers who choose level funding are accepting responsibility for their employees’ and dependents’ healthcare costs. Stop-loss coverage sets a ceiling, but the employer is still fundamentally in the risk business. A single catastrophic claim, a wave of chronic condition diagnoses, a dependent with a high-cost condition; any of these can reshape the claims picture in ways that follow the employer for years through renewal pricing. Before committing to a level-funded plan, employers need to be honest with themselves: are we prepared to be financially responsible for our employees’ healthcare spend?
Underwriting is a real gatekeeping factor. Carriers evaluate the group’s claims history and workforce demographics before offering a level-funded plan and setting monthly rates. A group with older employees, high utilizers, or recent high-cost claims may not qualify, or may find that level-funded pricing isn’t competitive compared to a fully insured alternative.
Year-over-year stability is not guaranteed. Stop-loss coverage protects within a plan year, but a high-claims year doesn’t go unnoticed at renewal. Stop-loss carriers reprice based on claims experience, which means a bad year can translate into substantially higher premiums the following year. Employers who’ve had two or three rough years in a row can find themselves priced out of the level-funded market entirely, or facing increases that erase the cost advantage they were counting on.
Group size limits access. Most carriers require at least 10 enrolled employees, and the model tends to work best for groups in the 50 to 200 range. Very small employers often have limited options, and pricing at small group sizes may not be competitive.
Geographic spread creates additional complexity. Level-funded plans work best when employees are concentrated in one region. For companies with employees across multiple states, network access, compliance requirements, and plan consistency become significantly harder to manage, and the single-carrier model that makes level funding feel simple starts to break down.
A quick refresher on ICHRA
An Individual Coverage HRA (ICHRA) is a defined contribution model. Instead of sponsoring a group plan, the employer sets a fixed monthly allowance and employees use it to purchase individual health insurance on their own, either through the ACA marketplace or off-exchange.
Employees choose the plan that fits them: their preferred doctors, their prescriptions, their household situation. They pay their premiums, submit documentation for reimbursement, and receive tax-free funds up to the employer’s set allowance. Any unused funds stay with the employer. Employees keep their individual plan even if they leave the company, which also eliminates COBRA administration on the employer’s end.
Here’s the risk picture with ICHRA: there isn’t one. The employer sets the allowance, pays it, and that’s the end of their financial exposure. It doesn’t matter if one employee has a catastrophic year or if the entire workforce has higher-than-expected utilization. The employer’s cost is fixed by design, not by a stop-loss policy with an attachment point and a renewal conversation attached to it.
ICHRA has no cap on employer contributions, no minimum group size requirements, and no participation minimums. Employers can vary contribution amounts based on employee classes including full-time versus part-time status, geographic region, and salaried versus hourly workers, and can adjust allowances annually. That flexibility in structuring contributions by class is one of the features that makes ICHRA particularly useful for employers with mixed workforces.
The model has grown substantially since it became available in 2020. ICHRA adoption among large employers (50 or more employees) increased 34% from 2024 to 2025, and small employer adoption was up 52% in the same period. Overall, adoption has grown more than 1,000% since launch.² Among employers offering ICHRA for the first time in 2025, 83% had not previously offered any coverage at all,³ a signal that ICHRA is opening the door to benefits for workforces that were previously uninsured.
How ICHRA and level-funded plans compare
Both models offer cost predictability and potential savings over fully insured plans. Beyond that, they’re built on fundamentally different assumptions about who should control the benefits decision and where the financial risk sits.
Cost control
With a level-funded plan, the employer controls plan design and captures savings when claims run low, but the final cost still depends on what actually happens with claims throughout the year. With ICHRA, the employer sets the allowance and that number is the ceiling. The employer never pays more than that amount, regardless of what employees’ individual plans cost or what medical expenses they incur.
Risk exposure
This is the sharpest dividing line between the two models. With a level-funded plan, the employer is bearing the financial risk of their employees’ and dependents’ healthcare costs. Stop-loss coverage provides a ceiling, but the employer is still fundamentally in the risk business. A bad claims year follows you into renewal. A catastrophic case can reshape your benefits budget for years. With ICHRA, that dynamic doesn’t exist. The defined contribution is the total exposure. Full stop.
Employee experience
Level-funded plans offer a familiar group plan experience: a single carrier, a shared network, consistent benefits across the workforce. Employees don’t have to do much, which is an advantage for workforces where simplicity matters. ICHRA requires employees to actively shop for and select their own coverage. That’s a bigger lift, and it requires thoughtful communication and support from the employer, particularly in year one when employees are navigating the individual market for the first time.
Employee choice
With a level-funded plan, the employer chooses the plan for everyone. All employees get the same coverage, whether or not it fits their individual situation. With ICHRA, employees choose their own plan based on their own doctors, prescriptions, and household needs. That distinction matters a great deal for employers with remote workers, part-time staff, or geographically dispersed teams where a single group plan will never be the right fit for everyone. An employee in Texas and another in Vermont are shopping in completely different markets and can each find what actually works for them.
Workforce fit
Level-funded plans work best for employers with a relatively healthy, geographically concentrated workforce and enough favorable claims history to underwrite well. ICHRA is purpose-built for geographic diversity, mixed workforce structures, and employers who want to offer benefits for the first time without building out a full group plan infrastructure.
Multi-state and remote teams
This is one area where ICHRA has a clear structural advantage. A company with employees in five states doesn’t need to manage five different networks or navigate varying state insurance requirements. The employer sets the contribution, and each employee shops the individual market in their own region. For level-funded plans, a distributed workforce isn’t impossible to accommodate, but it introduces meaningful complexity around network adequacy and compliance.
ACA compliance
For applicable large employers (50 or more full-time equivalent employees), ICHRA can satisfy the ACA employer mandate, but only if the allowance meets affordability thresholds based on each employee’s household income. That calculation requires attention, and getting it wrong has penalties attached. Level-funded plans, as ERISA-governed self-funded arrangements, have their own compliance requirements around ACA reporting, HIPAA, and plan documentation, and because they may not be required to cover all state-mandated essential health benefits, employers need to understand exactly what their plan does and doesn’t include.
Administration
Level-funded plans involve moderate ongoing overhead: monitoring claims data, evaluating stop-loss terms at renewal, and making plan design decisions each cycle. ICHRA administration is generally lighter, especially with a dedicated ICHRA platform handling reimbursement processing and compliance documentation, but employers still need to manage allowance design, class definitions, affordability calculations for ALEs, and employee communication.
How to think about which model fits your organization
The right answer depends on a few key variables, and the risk question should be the first filter.
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Consider a level-funded plan if:
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Your workforce is roughly 50 to 200 employees, concentrated in one or two regions
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Your claims history is favorable and your workforce skews younger and healthier
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You’re genuinely prepared to bear financial responsibility for your employees’ healthcare spend, understanding that stop-loss coverage manages but does not eliminate that risk
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You want direct control over plan design and benefit structure
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Your employees value the continuity and familiarity of a traditional group plan experience
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Consider ICHRA if:
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You want to remove claims risk from your benefits equation entirely
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You have a distributed or multi-state workforce where a single group plan creates network or coverage gaps
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You want a hard cap on health benefits spending that doesn’t depend on how healthy your workforce happens to be this year
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You’re offering benefits for the first time and want to start without the administrative complexity of a group plan
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Your workforce is mixed (full-time, part-time, seasonal, or some combination) and your employees would benefit from choosing their own coverage rather than sharing one plan
It’s also worth knowing that the two models aren’t always mutually exclusive. Some employers use ICHRA for specific employee classes such as part-time workers or employees in certain states, while maintaining a group plan for others. That kind of hybrid approach requires careful design, but it’s a legitimate way to address a workforce that a single model doesn’t fit cleanly.
The bottom line
Level-funded group health plans and ICHRA both give employers a path to more predictable, more strategic health benefits spending. But they represent fundamentally different stances on risk. Level funding keeps the employer in the risk business, with tools to manage and limit that exposure. ICHRA takes the employer out of the risk business entirely, replacing open-ended claims liability with a defined contribution the employer controls completely.
For employers who are cost-focused, have a healthy workforce, and are prepared to take on the responsibility that comes with self-funding, level funding is worth a serious look. For employers who want to know exactly what health benefits will cost regardless of what the year brings, ICHRA offers something level funding simply cannot: certainty.
The decision ultimately comes down to who your employees are, where they are, and how much claims variability your budget can absorb. Take Command works with employers navigating exactly this question. If you want to see how ICHRA could work for your specific workforce, contact a talk to a Take Command expert.
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References
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KFF. “2025 Employer Health Benefits Survey.” October 2025. https://www.kff.org/health-costs/2025-employer-health-benefits-survey/
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Becker’s Payer Issues. “ICHRA growth up 1,000% since 2020: 8 notes.” June 2025. https://www.beckerspayer.com/payer/ichra-growth-up-1000-since-2020-8-notes/
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HRA Council. “Growth Trends for ICHRA & QSEHRA, Vol. 4.” June 17, 2025. https://www.hracouncil.org/report
