Employers are offering cash-for-coverage plans to at least 500K
The HRA Council believes that at least 20,000 U.S. employers were using formal arrangements in January to provide cash that employees could use to buy their own individual or family health coverage, up from about 13,000 in January 2025.
The employers were probably providing coverage through individual coverage health reimbursement arrangements or qualified small employer health reimbursement arrangements for about 500,000 employees and dependents, according to results from a survey of 17 HRA Council member organizations.
See also: 5 things to know about ICHRAs
The council said it believes that the survey participants serve about 75% of the ICHRA plan and QSEHRA plan sponsors and participants, but they emphasized that they tried to be conservative when they came up with their estimates and believe that the current cash-for-coverage plan use numbers are probably higher.
This year, roughly two-thirds of the sponsors included in the data offered ICHRA plans, and one-third offered QSEHRA plans.
The median employer “allowance” per covered life was $459 per month, and the median premium that an eligible employee paid was $567 per covered life.
The typical employee paid $105 per month per covered life out of pocket to account for the difference between the allowance and the premiums.
The employer allowance covered the full cost of the premiums for 19% of the participating employees.
Survey: Good open enrollment period for 2026 despite worries
The HRA Council said its survey results show that council members ended up having a good open enrollment period for 2026, in spite of all of the uncertainty about how the U.S. health insurance market would work this year.
“Any ICHRA landscape analysis shows rapid expansion of the ecosystem in 2026, with new platforms launching and more brokerages and consultancies establishing ICHRA-focused teams and centers of knowledge and excellence,” the council said.
ICHRA counting: The council acknowledged in the new report that measuring use of ICHRA and QSEHRA plans has been difficult.
Even some council members opt not to participate in the council survey.
Brad O’Neill, the co-owner of the ICHRA Shop Insurance Agency, estimated in January 2025 that employers could be offering ICHRAs or other cash-for-coverage plans to as many as 5 million workers and dependents.
Paul Fronstin, an analyst at the Employee Benefit Research Institute, suggested in August 2025 that 300,000 to 700,000 workers and dependents could be using formal cash-for-coverage arrangements.
EBRI analysts published survey results in July that implied that 3.5% of employers with health plans, or as many as 100,000 employers, might be offering cash-for-coverage plans.
