Published by ICHRA Report September 11, 2026 · Sources reviewed through September 11, 2026 (America/Chicago).
The new EBRI–Morgan Health survey is evidence about employer awareness and interest. It helps identify decisions that need support, but it cannot establish how many employers will actually implement ICHRA.
Who was surveyed?
The July 28 chartbook reports an online survey of 984 benefits decision-makers conducted March 19–May 5. It includes 360 employers with 100+ employees offering health coverage, 308 smaller employers offering coverage, and 316 smaller employers without it. Employers had at least three employees. source
Respondents received an ICHRA explanation before later interest questions. Page 8 separates active implementation planning from exploration: 19% versus 43% for larger employers offering coverage, 14% versus 34% for smaller employers offering coverage, and 8% versus 34% for smaller employers without coverage. source
Read the decision stage before the percentage
Our interpretation is that “exploring” identifies demand for an evaluation process. It is not a purchase order, a signed administration contract or evidence that employees have enrolled. A survey response can be meaningful without being a reliable prediction of a future transaction.
The groups also matter. This study uses 100 employees to distinguish larger and smaller employers. That is not interchangeable with the applicable-large-employer boundary used elsewhere in benefits policy. Copying a percentage into an article about a different employer-size category would change the claim.
Do not pool the three segment percentages into a purported national adoption rate without an appropriate weighting method and population definition. A sample containing deliberately substantial groups does not automatically reproduce the distribution of all U.S. employers.
Translate interest into questions that can be answered
Network confidence is prominent in the published interpretations. The sponsor summary reports 89% for a network-related condition; the chartbook summary states 85%. We do not reconcile those into one headline percentage without a matching question and denominator. source source
The practical research question is more specific: can employees in the actual workforce find suitable plans? A useful evaluation should test clinicians, hospitals, prescriptions, premiums and support needs for real locations. Asking employers whether choice sounds appealing cannot answer those coverage questions.
HealthCare.gov’s framework supplies the underlying rules, while the employer’s own census and plan comparison establish practical fit. Those are distinct inputs to a decision. source
Read the sponsorship context
EBRI publishes the study’s sponsor list and says sponsors can provide questionnaire input. This is disclosed sponsored research, not an ICHRA Report employer survey. Sponsorship is relevant context; the appropriate response is to inspect the method and questions, rather than either discard or uncritically promote the findings. source
The study that should come next
A follow-up study could track the same employers from evaluation to implementation, non-adoption or postponement. It should record why decisions changed and whether the expected benefits occurred after launch. That would connect reported interest to observable outcomes.
For now, the survey supports investing in clear evaluation tools and local coverage analysis. It does not support forecasting revenue by multiplying every interested employer by an assumed conversion rate. Use our evaluation brief to move from general curiosity to documented requirements.
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.