We’ve worked with a brokerage that had clients who wanted to adopt an ICHRA, but they’re still pretty rare. If the employer has 50 FTE, it still has to contribute enough to the plan to satisfy the ACA affordability rules to avoid the ACA employer-mandate penalties. I haven’t looked at the math, but that might make the plans just as (or more) expensive to employers than many group health plans, which would limit their use by large employers.