1) Some people say that an Instrument Rating by itself is relatively useless without the practice to keep the holder current and proficient.
2) Most helicopters do not fly on IFR flight plans.
3) Most helicopter operators (even commercial operators) are not certified to perform IFR flights (e.g., Island Express).
4 Employers are loathe to allow pilots to regularly go out and "burn flight time" (or said another way, "waste flight time") while getting instrument current/proficient.
The blame for "the Kobe Bryant accident" can be laid squarely on Ara's shoulders. He evidently forgot that he was in a helicopter. When he got into worse and worse weather, he did not slow down. Just because he was in a big, sophisticated, twin-engine, IFR-capable helicopter, it was, in the end, no different from a 206. He *should* have slowed down, turned around, or made a precautionary landing. Those of us who've been in this business for a while have done all three of those things and lived to tell the tale. Ara did none of those things and made the rest of us look bad...oh, and killed Kobe Bryant in the process.