On May 22, the House narrowly passed the One Big Beautiful Bill Act of 2025, a sweeping legislative package that slashes over $1 trillion in healthcare spending - most notably through cuts to Medicaid, changes to Medicare, and tighter control over the Affordable Care Act (ACA) provisions.
But buried in the bill’s 11th-hour amendments and complex fiscal shifts are several consequential reforms that could reshape the way employers provide healthcare benefits. It still needs to pass the Senate.
Below, we break down six major provisions from the bill that will directly affect employer-sponsored healthcare plans, with added detail on what each means for HR leaders, brokers, and benefit consultants.
What changed?
The bill expands Individual Coverage Health Reimbursement Arrangements (ICHRAs) by allowing employees to use pre-tax dollars to purchase ACA marketplace (exchange) plans. For the first time, small employers who offer ICHRAs are eligible for a new tax credit (details pending Treasury guidance, but estimates suggest it could offset up to 50% of administrative and contribution costs for employers with fewer than 50 employees).
Why it matters:
ICHRAs allow employers to reimburse employees for individual health insurance rather than providing a group health plan. The concept was initially met with lukewarm reception but has gained traction in recent years, though still minimal adoption (less than 2%).
This bill signals an endorsement from the current administration, making ICHRAs a potentially central pillar of the future employer health plan landscape. With the exchange rules also being tightened (see #3), this move creates a more stable and predictable ecosystem for employers looking to shift toward defined contribution models.
Expected impact:
Estimates from policy analysts suggest that this provision could increase ICHRA adoption by 20–30% over the next three years, bringing potentially 2–4 million more workers into ICHRA arrangements by 2027. This is still just 5% of employees on employer-sponsored care, but a few more tweaks could continue to increase that number.
What changed?
The bill significantly loosens the rules around HSAs:
Why it matters:
These updates make HSAs far more versatile and attractive. For employers, pairing HSA-qualified high-deductible health plans (HDHPs) with expanded HSA usage can serve as a cost-control strategy while still supporting employee wellness.
The compatibility of Bronze and Catastrophic plans with HSAs also complements the ICHRA expansion, since many exchange plans fall into these tiers. It paves the way for consumer-driven health models that blend pre-tax benefits with individual choice.
What changed?
The bill implements a host of ACA exchange-related reforms, including:
Why it matters:
These changes aim to clamp down on fraud and subsidy misuse - issues that have dogged the exchange system since inception. Reports indicated that some individuals overstated income or took advantage of lenient re-enrollment policies.
From an employer perspective, particularly those using ICHRA models, this introduces both compliance pressures and risk mitigation benefits. While tighter enrollment rules may create more friction for employees navigating exchanges, they also stabilize the risk pool, potentially lowering premium volatility.
What changed?
The bill restores cost-sharing reduction (CSR) payments to insurers that serve the lowest-income ACA enrollees. These payments that were defunded in 2017. At the same time, it bars CSR funds for plans that include abortion coverage.
Why it matters:
CSR payments lower out-of-pocket costs for enrollees and stabilize insurance pricing. Their return is a boon to insurers, allowing them to offer lower deductibles and premiums on Silver-tier plans, particularly important for ICHRA participants who may rely on this tier to maximize value.
It’s also a subtle but significant endorsement of the ACA exchange infrastructure, reinforcing its viability for employer-funded individual insurance. In effect, this provision serves as another indirect boost to ICHRA success.
What changed?
While most of the PBM reforms target Medicare Part D and Advantage, the bill:
Why it matters:
These changes don’t directly apply to employer-sponsored commercial plans...yet. But PBM practices are under bipartisan scrutiny, and Medicare regulations often act as a precedent for broader industry reform.
Employers who self-fund plans or partner with third-party administrators (TPAs) could soon benefit from greater insight into drug pricing, rebates, and margins. At minimum, this raises employee awareness and expectation for cost transparency.
What changed?
The bill restricts lawful immigrant access to unsubsidized exchange coverage and makes DACA recipients ineligible for premium subsidies.
Why it matters:
For employers with diverse workforces - including those using ICHRA to cover part-time, seasonal, or contract labor - this provision introduces coverage challenges. Employees affected by these rules may face higher premiums or complete ineligibility for coverage options, potentially increasing uninsured rates.
This raises ethical and equity questions, particularly for organizations committed to Diversity, Equity, and Inclusion (DEI) principles. HR leaders may need to rethink how they support affected workers, or whether to offer alternative employer-funded benefits.
While the One Big Beautiful Bill is still awaiting Senate action and final reconciliation, its passage through the House offers a roadmap for where healthcare policy is heading, toward leaner federal spending, tighter exchange oversight, and growing support for consumer-driven models like ICHRAs and HSAs.
For employers, this means:
Now is the time for HR teams and brokers to evaluate how these shifts can be leveraged strategically—not just to stay compliant, but to build more flexible and cost-effective benefits for a changing workforce.