Like many industries, the employer-sponsored healthcare market is poised for transformative change. With mounting cost pressure, intensifying regulatory scrutiny, and increased demands for greatertransparency, 2025 will challenge longstanding assumptions about health benefits and the financing of healthcare. Employers, benefits providers, benefits consultants, and the entire benefits landscape writ large must brace for shifts that could reshape the industry for years to come.
Below are the key trends and developments I anticipate for 2025:
Increased Fiduciary Scrutiny of ASO Plans
Fiduciary accountability is tightening. On November 20, 2024, Owens-Minor Inc. became the first major U.S. employer to sue its administrative services only (ASO) provider, Anthem, over alleged withholding of claims data. The lawsuit alleges that Anthem’s lack of transparency obscured misuse of ERISA-regulated funds, such as illegal kickbacks to Anthem, double billing, and irregular repricing. Expect a wave of similar lawsuits as employers demand greater transparency from ASO arrangements offered by BlueCross, United, Cigna, Aetna, and Anthem (also known as the “BUCAs”).
Reevaluating Coverage of High-Cost Drug Categories
More employers will reconsider coverage of certain drug categories while trying to contain costs: this will take place in light of the continued rise of GLP-1s and other specialty pharmaceuticals, especially office-based infusions. 2024 saw no respite in the growth of these spend categories, and there’s no reason 2025 will be any different, as patient populations will continue to grow and therapeutic costs will remain elevated.
Potential Cap on Tax Deductibility of Health Benefits
Policy changes could disrupt the market. A cap on the tax deductibility of employer-sponsored health benefits has been floated as part of the anticipated tax negotiations in 2025. If enacted, this would likely represent one of the most significant shifts in U.S. health policy since at least the Affordable Care Act, or even since enaction of ERISA in 1974.
Rise of ICHRAs
Individual Coverage Health Reimbursement Arrangements (ICHRAs) are poised for wider adoption. With fiduciary scrutiny increasing, ICHRAs offer employers a compliant, cost-effective alternative for providing health benefits. The current administration’s focus on expanding these arrangements will accelerate their adoption in 2025.
Expansion of Alternative Financing Models
Large self-funded employers are seeking new ways to manage high-cost claims. Tools such as risk financing and captives will see greater interest, particularly among private equity-backed firms and at-risk health systems. Expect innovations in efficient funding of captives, and new technologies to optimize how capital is used for retained risk.
Continued Surge in Level Funding
Level funding is no longer a niche solution for small employers. The percentage of small businesses offering level-funded plans surged from 13% in 2020 to nearly 40% in 2023, according to the Kaiser Family Foundation. This trend will continue into 2025, as more employers seek the predictability and cost benefits that level funding offers versus fully insured.
Growing Potential for Group Purchasing of Health Benefits
Group purchasing strategies are evolving. Beyond captives, expanded association health plans (AHPs) could re-emerge as a viable tool. The Trump administration previously broadened AHP rules, and similar initiatives may resurface in the current term, giving employers more leverage in negotiating health benefits.
Conclusion
Employers navigating the 2025 healthcare market face a complex mix of legal challenges, rising costs, and policy uncertainties. Transparency, alternative financing, and innovative benefit structures will be central themes as the industry adapts. Staying ahead of these trends will require vigilance, strategic flexibility, and a willingness to embrace change. For those prepared to evolve, there are opportunities to not only manage costs but redefine what effective health benefits look like in the modern landscape.
Gerardo Zampaglione
Gerardo Zampaglione is Founder and Chief Product Officer of Aegle Capital, one of the first venture-backed companies in the $35 billion employer stop-loss market. Aegle is pioneering the use of adaptive capital for healthcare.
Zampaglione’s experience spans population health, value-based care, re/insurance program design, and predictive analytics to address healthcare challenges. Before founding Aegle, Zampaglione was a billing-focused population health lead at Epic Systems, the leading EMR vendor, where he implemented Epic’s enterprise billing modules and led population health-centric initiatives. He also held key roles at several boutique healthcare strategy consultancies, where he advised Fortune 500 biopharma, medical device, venture capital, and private equity firms on commercial growth strategy, due diligence, product design, and marketing—both in the U.S. and globally.
Zampaglione holds an MBA from the Wharton School of the University of Pennsylvania and a BA in Economics and International Relations from Tufts University. He serves on the Cell/Gene Therapy Taskforce and Future Leaders initiatives of the Self-Insured Institute of America.
