Published by ICHRA Report September 11, 2026 · Sources reviewed through September 11, 2026 (America/Chicago).
The HRA Council released Volume Five of its adoption research on August 12. The report adds useful evidence about employers and enrollment, but its headline growth figures should travel with the definitions and contributor boundaries behind them.
What was released
The association’s announcement presents the new report as evidence of continued HRA adoption. Its reporting hub identifies 17 contributing organizations. The underlying publication uses a January 31, 2026 observation date; an August release is not a live August enrollment count. source source source
We reviewed the full report and its methodology, rather than relying solely on the announcement. The important editorial task is to establish which figure describes an observed record, which includes dependents through an assumption, and which extrapolates beyond the contributing organizations.
Why the contributor base matters
Consider a hypothetical research program. If ten administrators submit data in one year and fifteen submit data the next, the total can increase even before accounting for growth within any administrator’s own book. A comparison restricted to organizations present in both years answers a different question from the expanded total.
Neither question is inherently useless. The expanded group can improve coverage of a market that researchers previously could not see. The repeated group provides a more consistent starting point for examining growth. Readers need both labels before they decide what a headline means.
How to read the release
Our adoption measurement analysis separates employees, estimated covered lives, market estimates and growth within a repeated contributor group. It also places a newer HealthSherpa channel update alongside the Council report without averaging incompatible estimates.
The contribution-data analysis examines the report’s allowance measures and explains why an employer should not adopt a national sample median as its own contribution budget.
Keep the larger Marketplace in its own column
CMS’s 23.1 million 2026 Marketplace plan selections measure the wider individual insurance market. They are not an ICHRA adoption count and do not include every off-Marketplace policy. source
The strongest use of the new research is to sharpen the questions employers, brokers and researchers ask next. What population is covered? Is the comparison stable over time? What would a result look like for a different workforce? A publication becomes more useful when those questions remain visible beside its numbers.
Sources and evidence
Review dates are recorded for each source above. Company pages are useful for confirming how a product is described, but they do not prove service quality or customer results.