Strong ICHRA Growth Among Large Employers Strengthens ACA Marketplace and Risk Pool, HRA Council Report Finds

New research shows more than 20,000 US businesses offer ICHRA or QSEHRA as a health
benefit in 2026 to at least 500,000 employees

WASHINGTON, Aug. 12, 2026 /PRNewswire/ -- The HRA Council, a non-partisan organization dedicated to improving and expanding health coverage options, today released Volume 5 of its annual report, "Growth Trends for ICHRA & QSEHRA," the most authoritative analysis of the adoption and impact of Health Reimbursement Arrangements (HRAs) across the United States.

The data proves the continued maturation of the Individual Coverage HRA (ICHRA) market, with sustained increases in adoption — particularly among larger employers offering ICHRA as a health benefit. For the first time, this report illustrates the effect that hundreds of thousands of HRA-covered lives have on the broader ACA market as a predominantly younger cohort of employees and their dependents select the best coverage for their lives and families.

"ICHRA is a compelling choice for employers of all sizes," said Robin Paoli, Executive Director of the HRA Council. "Even in a year of challenges for employers and the individual market, the HRA ecosystem is growing and scaling, covering more Americans and strengthening the risk pool for the ACA marketplace. ICHRA is a proven solution for employers who want to provide affordable health coverage and employees who want to choose the quality insurance plan that works best for them."

The report aggregates data from 17 HRA Council member organizations, offering insights into enrollment trends, employer adoption rates, and the plans that employees are choosing for themselves and their families. Key findings from the 2026 report include:

• ICHRA is becoming a first choice for ALEs. Applicable Large Employers (ALEs) represent the fastest growing segment of ICHRA adoption, more than doubling on average since last year. Larger and larger employers are choosing ICHRA as a best fit for employees, not simply a stopgap response to group coverage price hikes. And these employees often are experienced consumers of coverage and care, accustomed to yearly physicals and wellness programs that identify and manage health risks.

• More than half of enrollments both on- and off-exchange are by employees under the age of 45: ICHRA employees are younger than pre-existing ACA individual planholders, and they're choosing Silver and Gold more than other metal tiers. This year's data allows for a deeper look at not only the risk profile but also employee spending and employer allowance behaviors.

• HRAs continue to be an on-ramp to benefits for small employers: More than two-thirds of small businesses offering ICHRA and 93% of those newly offering QSEHRA in 2026 previously offered no health coverage to their employees. Nearly a third of small employers who have adopted ICHRA moved from the often challenging small group market.

• Employees are customizing their own coverage: Employees are embracing a consumer mindset to select their preferred level of coverage for their healthy lives and circumstances. Some people choose plans whose monthly premiums are less than the employer contribution and use the savings on other approved items, and some employees add $100+ per month in addition to their employer contribution, to secure richer coverage.

Insurers, administrators, and benefits consultants faced unprecedented challenges covering employees for the 2026 plan year, including the expiration of Enhanced Advanced Premium Tax Credits and other changes. In this context, ICHRA proved durable. The data suggests the number of ICHRA-covered lives alone (not including the thousands of QSEHRA-covered lives) surpassed 500,000 at the beginning of 2026.

State policymakers are taking note of this vibrant national ecosystem, recognizing ICHRA as a way to give more constituents access to health coverage. The National Conference of Insurance Legislators (NCOIL) unanimously approved nonpartisan model legislation for state tax credits. Policymakers are working to help contain health care costs in their states by offering employer incentives for HRA adoption, and are increasingly looking at ICHRA as an option for their own state employees.

For more information, and to access the full Volume 5 report, please visit the HRA Council's Data Reporting Hub at www.hracouncil.org/report.

Research Methodology

At the end of open enrollment, HRA Council members — who either directly administer ICHRA and QSEHRA for employers, directly facilitate employee plan shopping and enrollments, or both — were invited to share anonymized record-level data for the upcoming benefit year as of Jan. 31. This report compares both aggregate growth in employer adoption based on all available data and a returning cohort of growth data from members who shared in both 2025 and 2026.

About the HRA Council

The HRA Council is a non-partisan, nonprofit trade association dedicated to educating employers, policymakers, and industry about defined contribution health and wellness benefits, and expanding health coverage access and affordability for American workers. Through collaboration with industry leaders, policymakers, and stakeholders, the Council provides education, research, and advocacy to support the evolution of employer-sponsored health benefits.

SOURCE HRA Council