Published by ICHRA Report September 11, 2026 · Sources reviewed through September 11, 2026 (America/Chicago).
A published contribution median is a reference point, not a recommendation for an employer’s allowance. The unit of measurement and local workforce matter as much as the dollar amount.
The reported figures
Page 6 of HRA Council’s 2026 report presents a $459 median allowance, $567 median premium and $105 median “flex up,” each per covered life. The chart covers ICHRA and QSEHRA, on- and off-Exchange, and reports an 81% allowance-to-premium ratio. These are sample measures, not an ICHRA-only national employer benchmark. source
Start with the unit
An allowance per covered life is not necessarily an allowance per employee. A household containing dependents can produce a very different per-person result from an employee-only household. The employer needs to know whether its budget is defined per eligible employee, participating employee, policy, household or covered person.
For illustration, an employer budgeting $600 for a participating employee’s household has not necessarily committed $600 for each covered person. Recasting the amount without changing the denominator would create a misleading comparison. This example explains the unit; it is not a contribution recommendation.
Why subtracting the medians can mislead
The two published medians produce an arithmetic difference of $108. That does not establish an error in a separately reported $105 median gap. In general, the median of paired differences is not equal to the difference between two medians.
A simple illustrative dataset shows why. Suppose three paired allowances and premiums are $100/$200, $200/$210 and $300/$1,000. The allowance median is $200 and the premium median is $210: a $10 difference. But the individual gaps are $100, $10 and $700, whose median is $100. These are invented numbers used solely to demonstrate the mathematics.
Build the employer’s budget from its own inputs
Start with the workforce’s locations, ages, household assumptions and eligible classes. Obtain premiums for the relevant plan year and geography. Then compare the employer’s total cost and the employee’s premium exposure across contribution scenarios.
The IRS’s 2027 required contribution percentage is 10.22%; it is a compliance input, not a national competitive-benefit target. CMS’s reviewed lookup dictionary describes 2026 data and its platform coverage. A 2026 lookup should not silently become a 2027 premium assumption. source source
HealthCare.gov explains the permitted ICHRA contribution structure. Once a design satisfies applicable requirements, a separate judgment remains: will employees consider the benefit useful and workable for their needs? source
What a stronger benchmark would include
An employer needs matched comparisons by geography, age, household, employer size and benefit design, with counts and missing-data disclosures. Ideally the evidence would also describe what employees actually paid, whether they enrolled and what happened at renewal.
ICHRA Report has not collected that proprietary dataset. This analysis establishes a disciplined way to use external figures while identifying the fields needed for future original research. See the contribution modeling guide for the broader process.
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.