There’s a type of risk that announces itself. A lost client, a missed renewal, and a competitor who undercut your pricing, to name a few. These are the risks that show up in your pipeline reports and prompt immediate action.
But there’s another kind of risk that’s quieter, slower, and in many ways more dangerous: the risk of stagnation. It’s the gradual realization that the market shifted while you were focused on managing what was already in front of you.
For TPAs, that second type of risk is very real right now. Two benefit products in particular – HSAs and ICHRAs – are not emerging trends to monitor from a distance. These accounts are products employers are already asking for. Administrators who aren’t ready for the shifting benefits landscape are falling behind though they may not realize it just yet.
HSAs: From Perk to Baseline Expectation
It’s easy to treat HSAs as familiar territory. TPAs have been administering them for years, and the mechanics are well understood. But familiarity can be misleading. The scale of the HSA market has changed substantially, and the demographic data tells a story worth close attention.
Total HSA assets reached nearly $159 billion across more than 40 million accounts as of mid-year 2025, representing 16% year-over-year growth. Devenir projects the market will surpass 47 million accounts and approximately $208 billion in total assets by the end of 2027.
Those are significant numbers on their own, but the more telling signal is who’s driving this growth. More than half (56%) of Gen Z workers now report holding HSAs, as do 50% of Millennials – significantly outpacing Gen X at 35% and Baby Boomers at 24%.
This is not just an account-holder data point; it reflects a fundamental shift in workforce expectations. Younger employees aren’t passively accepting HSAs as a benefits add-on. They’re actively incorporating them into their broader financial strategies. For this generation, a competitive benefits package includes robust HSA functionality as a baseline rather than a differentiator.
In other words, the demand for experienced, capable HSA administration is not plateauing. As high-deductible health plans continue to spread across employer sizes and industries, employer clients who haven’t yet asked about HSA administration will be asking soon.
TPAs who haven’t built the necessary infrastructure and expertise will find themselves scrambling to catch up at exactly the moment the volume demands they perform.
ICHRAs: Accelerating Faster Than Anyone Expected
If HSAs represent a maturing market with sustained momentum, ICHRAs represent something different. The ICHRA market shows a growth curve that continues to get steeper and move faster than many in the industry anticipated.
ICHRA adoption has grown more than 1,000% since 2020, with employers across all size segments continuing to adopt at double-digit rates year after year. Large-employer ICHRA adoption jumped 34% from 2024 to 2025 alone, with some employer cohorts showing 49% year-over-year growth. Among smaller employers, non-ALE ICHRA adoption among HRA Council founding members increased 52% in the same period.
What makes these numbers especially significant is what’s happening on the retention side. Better than nine out of ten (92%) of employers who offered an HRA in 2024 renewed it in 2025. When a product achieves that level of stickiness, it signals something beyond a trend; it signals a structural shift in how employers are approaching benefits.
And perhaps the most telling near-term indicator: HRA Council members are reporting 400–800% increases in employer requests for ICHRA quotes for 2026 and 2027. Centene, the largest marketplace carrier in the United States, recently established a division wholly dedicated to ICHRA promotion.
When insurers of that scale build entire business units around a product, the window for early positioning doesn’t remain open indefinitely.
What Real Preparation Looks Like
Being ready for these shifts in the benefits landscape isn’t about having general awareness that HSAs and ICHRAs are growing. It’s about having the platform, the processes, and the operational capacity to administer them at scale before your clients are waiting on you to figure it out.
In practical terms, that means managing complex plan designs across HRA types — ICHRAs, EBHRAs, QSEHRAs, and traditional HRAs — from a single, integrated system. It also means handling HSA accounts, investments, and banking without routing clients through a patchwork of vendors.
Another high priority need is having the full operational infrastructure in place: claims adjudication, enrollment support, and a knowledgeable contact center capable of delivering a seamless experience when volume spikes.
The benefits market is moving with unusual speed and clarity of direction right now. The TPAs positioned to win when demand peaks won’t be the ones who react fastest. They’ll be the ones who started preparing the earliest.
Choose a Partner That’s Invested in Your Growth
Equip your organization now for the future of consumer-directed healthcare administration by partnering with DataPath for cutting-edge technology and operational expertise. Our comprehensive solution delivers integrated plan management for HSAs, ICHRAs, and the entire suite of consumer-directed healthcare accounts; HSA investment tools; extensive business processing; human-staffed contact center support; and more.
The window is still open — but it won’t be forever. Are you ready to start the conversation?