Twelve questions that tell you who actually runs the insurance
Every ICHRA platform will tell you they're accountable. None of them can fake an org chart. These are the questions where the honest answer has to be structural: a name, a number, a contract, instead of an adjective.Twelve questions reveal whether an ICHRA administrator holds its own carrier appointments, employs its own support staff, and can enroll members off-exchange. ICHRA platforms look nearly identical in a demo, because on-exchange the plans are the same no matter whose software displays them. The differences are underneath. Ask these of every vendor you're considering, including Kyra.
How to use this
Ask every vendor the same twelve, in the same order, and write the answers down. You're not looking for the best-sounding response. You're looking for specificity: a number, a name, a document, an offer to show you. A vendor who answers "we're deeply committed to member advocacy" has told you they don't have a roster to show.
Group 1: Who owns the insurance operation
1. Are your carrier appointments direct, or are you selling on someone else's paper?
Why it matters — An appointment held through an upline or FMO means the platform can't call the carrier as a contracted party. Every escalation goes through someone else's company.
A real answer: "Direct, in our own name. We'll show you the contracts under NDA."
A dodge: "We have relationships with all the major carriers."
2. How many appointments do you hold, and will you show the contracts in diligence?
Why it matters — A count is checkable. An adjective isn't. And the willingness to show contracts is itself the answer.
A real answer: A specific number, and yes.
A dodge: "Hundreds," or "all the carriers you'd need."
3. In which states are you licensed as an agency?
Why it matters — Licensure gaps show up as members who can't be serviced where they live. It's a list, not an opinion.
A real answer: The list, or "all fifty."
A dodge: "We serve clients nationwide." Serving isn't licensing.
4. Can you enroll members off-exchange, or only on-exchange?
Why it matters — Off-exchange plans carry different tax treatment for the employee's contribution and often better options. On-exchange-only platforms have a smaller shelf.
A real answer: "Both," and they'll show you in the demo.
A dodge: Redirecting to how good the marketplace options are.
Group 2: Who does the work
5. Who employs the person who calls the carrier when an employee is terminated by mistake? Can I meet them on this call?
Why it matters — This is the whole thing in one question. If the answer is a vendor, you inherit their queue.
A real answer: A named team, on their payroll, brought onto the call.
A dodge: "Our support team handles all escalations."
6. What does your member-support staffing look like in March versus November?
Why it matters — Most of this category is built for open enrollment and goes quiet the other ten months. The ratio tells you which kind of company you're buying.
A real answer: Two numbers, and they're close.
A dodge: "We scale to meet demand." That means seasonal contractors.
7. When a member calls, do they reach someone who knows insurance, knows this platform, and knows my client?
Why it matters — Overflow call centers fail all three. The member gets a part-time rep reading a script.
A real answer: A description of who picks up, and their training.
A dodge: Response-time SLAs offered instead of an answer about competence.
8. What's your escalation path, and what's the record of the work?
Why it matters — If there's no audit trail there's no accountability, and you'll be the one reconstructing what happened.
A real answer: A walkthrough of the actual system, with timestamps.
A dodge: "Everything's tracked in our platform."
Group 3: What happens when it breaks
These four expand the four scenarios from our ICHRA guide into vendor questions. Ask for a step-by-step walkthrough of each: who touches it, in what system, how fast, with what record.
9. Walk me through moving a 200-life group off its plan.
Who educates the employees? What happens to the person who never picks anything? How is day-one coverage guaranteed?
10. A premium payment fails and the carrier moves to terminate.
Who notices, and when? Who makes the call? How does the policy get reinstated, and how fast?
11. Same question, but a claim denial at a small regional carrier.
The second answer is the revealing one. The member on the obscure carrier is the one who gets orphaned everywhere else.
12. What's your plan if your enrollment infrastructure has an outage during open enrollment?
Shared third-party infrastructure means an outage is a category-wide event you wait out with everyone else.
Evidence to ask for, beyond the twelve
- Published service commitments, with what happens when they're missed
- NPS with its methodology and sample size. A score without an n is a number, not evidence
- Retention data across a full renewal cycle
- References chosen for in-year service, not implementation. Anyone can produce a happy customer three weeks after go-live
A note on public appointment records
You may be tempted to look a vendor up in state appointment filings. Don't rely on it. Many states don't file appointments at all, and the records can't distinguish a direct carrier contract from one running through an upline. Ask for the contracts instead, and ask every vendor to match.
Since you're going to ask us anyway
Direct carrier appointments, contracts available in diligence. Licensed as an agency in all fifty states. On-exchange and off-exchange. Carrier relations and member advocacy are salaried Kyra employees you can meet on the call, staffed at the same level in March as in November. Medicare handled in-house.
Where we'd rather you didn't take our word for it, ask for the document.