Study examines how ICHRA adoption could help stabilize ACA risk pools
With the instability in the Affordable Care Act's marketplaces, proponents of ICHRA have suggested that these models could help support the risk pools.
The HRA Council, a nonpartisan nonprofit promoting expanded coverage options, released a new survey examining the growing adoption of Individual Coverage Reimbursement Arrangements (ICHRAs) in response to instabilities within the Affordable Care Act marketplaces. The research indicates that a larger number of larger employers are considering ICHRAs as a potential solution, which could help stabilize risk pools by attracting younger, healthier individuals into the market.
According to the report, the number of employers offering ICHRAs nearly doubled from 6,600 in 2025 to 12,700 by January 2026, representing a 109% growth among firms with 500 to 999 employees and a 178% growth among those with over 1,000 employees. Robin Paoli, executive director of the HRA Council, explained that these larger employer adopters are crucial in strengthening the broader individual market risk pool, as more people come in to join it.
The survey also found that more than half of ICHRA enrollments, both on- and off-exchange, are among people under the age of 45. When offered as an option, many individuals choose to "flex up" to a higher-tier plan, adding their own money on top of the employer stipend. On average, the median allowance offered to employees was $459 per month, while the median premium selected was $567. Employees tended to prefer silver- or gold-tier plans, particularly younger enrollees.
One of the key benefits of ICHRA is its ability to allow individuals or families to choose the coverage that best meets their specific needs. The study shows that patients are making these choices through a trend of flexing up to higher-tier coverage. Furthermore, the HRA Council reports that ICHRA continues to provide an on-ramp to coverage for small businesses, with more than two-thirds of small employers offering ICHRAs having no benefits available previously, while the remaining third transitioned from a complex small group market.
Many small businesses are also reportedly embracing a Qualified Small Employer Health Reimbursement Arrangement (QSHERA) before transitioning to ICHRA, as they recognize the flexibility and potential benefits it can offer as they grow.
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