# The 2027 ICHRA planning outlook: what is known and what still needs a local answer

Canonical reader page: https://ichrareport.com/research/ichra-2027-planning-outlook/

Publisher: ICHRA Report

Originally published: 2026-09-12

Substantively updated: 2026-09-22

Sources checked: 2026-09-22

Data period: Planning evidence reviewed September 22, 2026; Maryland landscape remains preliminary

[Home](https://ichrareport.com/) [Research](https://ichrareport.com/research/)  The 2027 ICHRA planning outlook: what is known and what still needs a local answer

2027 outlook

Preparing an ICHRA for 2027 requires checking contributions, enrollment dates and local insurance availability together. Use this report to distinguish published national information from the employee and county-level details your planning team still needs.

At a glance

Evidence  **Analysis of external evidence**

Event / data period  **Planning evidence reviewed September 22, 2026; Maryland landscape remains preliminary**

Review cutoff  **September 22, 2026**

By [ICHRA Report](https://ichrareport.com/about/) · Published  September 12, 2026  · Updated  September 22, 2026

Planning conclusion

The 2027 ICHRA decision should be built from several current inputs: the correct affordability percentage, current enrollment instructions, local carrier availability and a contribution model for the workforce. A national market headline cannot replace any of them.

## What is established in the reviewed sources

| Input | Reviewed position | Employer consequence |
| --- | --- | --- |
| 2027 affordability | IRS required contribution percentage: 10.22%. | Use the correct plan-year calculation. |
| Federal open enrollment | CMS guidance: November 1, 2026–January 15, 2027. | Separately confirm the deadline for the intended coverage start. |
| Cigna individual/family medical | Company notice says no 2027 offering. | Identify affected employees and local replacement options. |
| Reviewed CMS premium dictionary | Describes 2026 data. | Do not label those premiums as verified 2027 rates. |

Sources for these planning inputs: [source](https://www.irs.gov/irb/2026-31_irb) [source](https://www.cms.gov/files/document/statement-re-city-columbus-080426.pdf) [source](https://shopifp.cigna.com/) [source](https://www.cms.gov/files/document/ichra-employer-lowest-cost-silver-plan-premium-look-up-table-data-dictionary.pdf)

## New state-market signals for 2027

Four September sources show why evidence type and approval status have to travel with every number. An approved weighted market average, a preliminary plan inventory and a final employee-level premium answer different questions. They cannot be averaged into a national ICHRA trend or one state score.

| Source and plan year | Scope and status | Observed metric | What it cannot establish |
| --- | --- | --- | --- |
| Washington · 2027 Decision September 9 | Exchange individual market; approved average | 22.2% average increase | Each plan, county or employee's lowest-cost Silver change |
| Connecticut · 2027 Decision September 11 | Individual and small group, on and off exchange; approved averages | 11.3% individual; 15.1% small group | Which arrangement costs less for the same workforce |
| Pennsylvania · 2027 Decision September 18 | Individual and small group; approved weighted averages | 15.97% individual; 10.28% small group | Actual local plan prices or an ICHRA-versus-group result |
| Maryland · 2027 Presentation September 21 | Exchange individual-plan inventory; rate and form approval pending | 43 plans in 2026 and 43 in 2027, with mix changes | Final approval, premiums, networks or affordability |

Sources: [source](https://www.insurance.wa.gov/about-us/news/news-archive) [source](https://portal.ct.gov/cid/press-releases/2026-press-releases/2026-09-11-health-insurance-rate-decision-for-2027) [source](https://www.pa.gov/agencies/insurance/newsroom/pennsylvania-releases-aca-2027-health-insurance-rates) [source](https://www.marylandhbe.com/2026-board-documents/) [source](https://www.marylandhbe.com/wp-content/uploads/2026/09/2027-Individual-Market-Plan-Landscape.pdf)

Read the underlying updates: [Washington's individual-market decision](https://ichrareport.com/news/washington-2027-individual-market-rates-ichra/), [Connecticut's paired decision](https://ichrareport.com/news/connecticut-2027-individual-small-group-rates/), [Pennsylvania's individual and small-group rates](https://ichrareport.com/news/pennsylvania-2027-individual-small-group-rates/) and [Maryland's preliminary plan lineup](https://ichrareport.com/news/maryland-2027-individual-market-plan-landscape/). Use them as prompts to refresh local inputs, not as substitutes for plan-level evidence.

## Carrier participation: an updated signal, not a local plan count

In narrative dated September 15, KFF reports nine carrier groups announcing exits from some or all of their state ACA Marketplaces for 2027, and six announcing entry into new state Marketplaces. Its notes group insurers by parent company. These counts describe different geographic moves; subtracting six from nine would not measure a national net loss of three insurers or any employee's available plans. [source](https://www.kff.org/affordable-care-act/tracking-insurer-participation-changes-in-the-aca-marketplaces-in-2027/)

The same page retains a table-source note dated July 2, 2026. We preserve that inconsistency rather than treating the table as a fully reconciled September county inventory. We have not identified a specific additional entrant from a documented revision history. State-specific conclusions require current exchange, regulator or carrier records. [source](https://www.kff.org/affordable-care-act/tracking-insurer-participation-changes-in-the-aca-marketplaces-in-2027/)

| Check for the employee's location | Why it is a separate question |
| --- | --- |
| Participating carriers and exact plans | A state announcement does not establish every county's plan inventory. |
| Provider networks and formularies | A familiar insurer name does not establish access to a particular doctor or prescription. |
| The employee's selected-plan premium | This helps describe the employee's actual premium cost after the contribution. |
| Applicable lowest-cost self-only Silver premium | The affordability benchmark is a separate input; it need not be the plan the employee chooses. |

Use the [network and prescription checklist](https://ichrareport.com/guides/keep-doctor-with-ichra/), [employee contribution examples](https://ichrareport.com/guides/same-allowance-different-experiences/) and [2027 affordability guide](https://ichrareport.com/guides/ichra-affordability-2027/). The latter separates the employee premium-tax-credit test from employer-shared-responsibility analysis and applicable safe harbors. Do not substitute a general market average for the required input. [source](https://www.healthcare.gov/small-businesses/learn-more/individual-coverage-hra/) [source](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit)

The [Market Explorer](https://ichrareport.com/tools/market-explorer/) remains a scoped 2026 public-data resource, not a live 2027 quote engine. A new employer record, such as [Alliance Entertainment's disclosed transition](https://ichrareport.com/research/alliance-entertainment-ichra-sec-filing/), also does not establish the quality of insurance in any employee's location.

## The local evidence still needed

This review does not establish final 2027 premiums for every county, each employee’s eligible plan menu, provider-network continuity or the outcome of every state filing. A requested rate change is not necessarily an approved rate, and an insurer’s national announcement is not a substitute for an employee-specific plan comparison.

Build the analysis so an updated premium or carrier record can replace an assumption without rewriting the entire proposal. Record the plan identifier, geography, year, source and date alongside the amount. Mark preliminary inputs visibly.

## Compare costs from both sides

The employer’s model should include contributions, administration, implementation and any related service costs. The employee’s model should include the premium remaining after the allowance, the policy’s cost-sharing structure and relevant coverage needs.

Use several scenarios rather than one average employee. A young employee in one county and an older employee in another may face different premiums and networks. An apparently stable employer budget can coexist with a substantial change in an employee’s experience.

The employee’s premium-tax-credit position requires its own evaluation. An ICHRA offer is not interchangeable with a cash raise that leaves Marketplace eligibility untouched. [source](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit)

## Translate the model into an operating schedule

Once the model is credible, assign responsibility for the plan documents, notices, employee education, enrollment, payment confirmation and issue resolution. HealthCare.gov’s guidance explains the ICHRA framework, including notice requirements; the administrator should explain how those requirements map to the actual launch date. [source](https://www.healthcare.gov/small-businesses/learn-more/individual-coverage-hra/)

Then test the workflow before launch with representative cases. Follow an employee who needs help choosing a policy, an employee who opts out and an employee whose first payment encounters a problem. These exercises reveal operational gaps that a contribution spreadsheet will not show.

## What would make the decision ready?

A reviewable decision packet should contain the workforce assumptions, dated local plan evidence, contribution scenarios, employee impact, provider responsibilities and unresolved questions. Use the [free evaluation brief](https://ichrareport.com/tools/ichra-readiness/) to organize that packet.

This is a planning synthesis of external evidence, not a prediction that ICHRA will be cheaper or better for every employer in 2027. New rates, guidance or carrier information should trigger updates to the affected input and the conclusions that depend on it.

## Sources and evidence

[1 Internal Revenue Service — Revenue Procedure 2026-26 Section 3.02 sets the required contribution percentage at 10.22% for plan years beginning in 2027. Section 5 establishes the effective period. Source reviewed 2026-09-11](https://www.irs.gov/irb/2026-31_irb)[2 CMS — Updated statement regarding City of Columbus v. Kennedy Two-page August 4 statement describes the July 16 stay of specified 2027 rule provisions and the November 1–January 15 federal enrollment period. Litigation remains subject to change. Source reviewed 2026-09-11](https://www.cms.gov/files/document/statement-re-city-columbus-080426.pdf)[3 Cigna Healthcare — Individual and family medical plan shopping notice Undated notice checked September 11: individual/family medical plans will not be offered for 2027; dental continues. Does not describe Cigna group coverage. Source reviewed 2026-09-11](https://shopifp.cigna.com/)[4 CMS — ICHRA premium lookup data dictionary Reviewed dictionary describes 2026 lowest-cost Silver data and geographic/platform scope. It is not a verified 2027 premium table. Source reviewed 2026-09-11](https://www.cms.gov/files/document/ichra-employer-lowest-cost-silver-plan-premium-look-up-table-data-dictionary.pdf)[5 HealthCare.gov — Individual Coverage Health Reimbursement Arrangements Federal overview of ICHRA contributions, employee classes, class-size minimums, affordability, and implementation timing. Source reviewed 2026-09-11](https://www.healthcare.gov/small-businesses/learn-more/individual-coverage-hra/)[6 Internal Revenue Service — Questions and answers on the Premium Tax Credit Current premium-tax-credit affordability percentages and interaction with employer-sponsored coverage. Source reviewed 2026-09-11](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit)[7 Washington State Office of the Insurance Commissioner — Average 22.2% rate increase approved for Washington's 2027 Exchange individual market The September 9, 2026 official archive entry reports a 22.2% average actuarially justified increase versus 22.4% requested. The article omits the carrier count because another official OIC page displayed a conflicting count at review time. Source reviewed 2026-09-14](https://www.insurance.wa.gov/about-us/news/news-archive)[8 Connecticut Insurance Department — 2027 health insurance rate decisions for individual and small-group plans The September 11, 2026 decision reports average approved increases of 11.3% for individual plans and 15.1% for small-group plans, compared with 16.2% and 17.8% requested. The approximately 220,000 enrollment figure combines both markets. Source reviewed 2026-09-14](https://portal.ct.gov/cid/press-releases/2026-press-releases/2026-09-11-health-insurance-rate-decision-for-2027)[9 KFF — Tracking Insurer Participation Changes in the ACA Marketplaces in 2027 Page says originally June 11; narrative as of September 15 reports nine exiting and six entering parent-company groups. July 2 table-source note persists. Not net national carrier loss or county plan counts. Source reviewed 2026-09-17](https://www.kff.org/affordable-care-act/tracking-insurer-participation-changes-in-the-aca-marketplaces-in-2027/)[10 Pennsylvania Insurance Department — Pennsylvania Insurance Department Releases Affordable Care Act 2027 Health Insurance Rates Final weighted average rate changes for Pennsylvania's individual and small-group markets. Statewide and carrier averages are not employee-level premiums, lowest-cost Silver benchmarks or ICHRA-versus-group cost results. Source reviewed 2026-09-22](https://www.pa.gov/agencies/insurance/newsroom/pennsylvania-releases-aca-2027-health-insurance-rates)[11 Maryland Health Benefit Exchange — 2026 Board Documents — September 21 meeting Official board page linking the 2027 individual-market qualified-health-plan landscape. The posting date is distinct from final rate or form approval. Source reviewed 2026-09-22](https://www.marylandhbe.com/2026-board-documents/)[12 Maryland Health Benefit Exchange — 2027 Individual Market Qualified Health Plan Landscape Nine-page state-exchange presentation. Its cover says 2027 rate and form approval is pending. Aggregate plan counts, service areas and ranges are not final premiums or employee-level affordability results. Source reviewed 2026-09-22](https://www.marylandhbe.com/wp-content/uploads/2026/09/2027-Individual-Market-Plan-Landscape.pdf)

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.