Big companies eye ICHRAs for just some employee groups 

June 10, 2026

In our latest Survey on Health and Benefits Strategies, we asked employers about their interest in switching from a group employer-sponsored health plan to an individual coverage health reimbursement arrangement, with separate options for switching to ICHRAs for all employees versus certain employee groups (e.g., part-time, hourly). While interest in either option overall is relatively low, the smallest employers were more likely to express interest in offering an ICHRA to all employees. 

The largest employers were more likely to express interest in offering an ICHRA just to certain groups. Among employers with fewer than 200 employees, 13% expressed interest in offering an ICHRA to all employees, and 8% in offering it only to certain groups. Looking at the largest employers, 5,000 or more employees, 9% are interested in offering an ICHRA just to certain groups, and 6% to all employees. 

It’s important to remember that this survey is for employers that already offer health coverage. The latest report from the HRA Council indicates that 83% of employers offering an ICHRA had not previously provided any health benefits — suggesting that ICHRAs are playing a role in expanding access to health coverage, particularly among small businesses, rather than displacing traditional group plans. Clearly, it would be far more disruptive to move employees from an existing group plan to an ICHRA than to offer an ICHRA to employees that have not been offered any health benefits before. In today’s tough cost environment, some employer health plan sponsors are willing to at least consider disruptive changes such as switching to ICHRAs. But we should note that survey respondents were asked to rate their interest level on a 5-point scale. The data in the chart represent those saying either “very interested” or “somewhat interested” – but very few (almost none) selected “very interested.”

What you need to know about the option to offer ICHRAs to “certain groups:” The rules allow employers to vary eligibility and contribution amounts by employee classes (FT/PT, salaried/hourly, geography, union status, and more) — enabling targeted benefit strategy. ICHRAs must be offered to all employees within a permissible class on the same terms and conditions. Given the significant compliance issues, employers interested in exploring this approach should start with a compliance discussion and a feasibility assessment. 

How fast are ICHRAs really growing? When the rule expanding ICHRAs was finalized in 2019, the federal government expected relatively swift adoption, projecting that around 11 million individuals would get their coverage through an ICHRA by 2025 (out of approximately 160 million people who get their health benefits through their employers). The reality is nowhere near that. In 2025, EBRI estimates that between 350,000 and 700,000 workers and their dependents are covered by an ICHRA. While there have been reports of big growth in ICHRA enrollment for 2026, those reports are typically vendor-specific and provide the percentage increase in their own enrollment, which is not a good indication of enrollment growth overall. While we await data on current enrollment, keep in mind that, even with strong growth, because the groups are small it’s unlikely that national enrollment will surpass 2 million.

ICHRAs are certainly a different animal than traditional group coverage. Whether ICHRAs could be your next big strategy will depend in large part on the funding requirements, administration and evaluation of the individual market in your locations.