Published by ICHRA Report September 11, 2026 · Sources reviewed through September 11, 2026 (America/Chicago).
There is evidence of ICHRA growth, but no complete national census in the sources reviewed. The useful question is which part of the market each measurement can establish.
The measures are different
| Source measure | Reported value | Boundary |
|---|---|---|
| HRA Council: known participating employees | 261,000 | January 2026; page 8 |
| HRA Council: covered lives | 402,000 | Derived using a 1.54 dependent factor; not a direct count of unique member records |
| HRA Council: broader covered-life estimate | 500,000+ | Includes an allowance for coverage outside its contributors |
| HealthSherpa: national market estimate | Above 1 million members | Company estimate in a mid-year update; not its own enrollment count |
| CMS: 2026 Marketplace selections | 23.1 million | Wider Marketplace, not an ICHRA count |
The HRA Council figures come from its report; HealthSherpa’s estimate comes from its company-channel post. CMS measures a different insurance population. These figures must not be added together or averaged. source source source
A stable comparison changes the growth story
HRA Council’s page 9 reports ALE growth of 108% in its expanded aggregate and 39% in the repeated prior-year contributor cohort. The corresponding non-ALE figures are 97% and 33%. New contributors affect the aggregate comparison. source
Our analytical preference is to use a repeated contributor group when describing change within an observed population. Use the expanded total when describing the research program’s broader reach. Even a repeated group is not a random national sample: changes within the group can include transfers from administrators outside it.
For example, an administrator gaining an employer from another administrator increases its own book but does not necessarily add an employer to the category. A national adoption measure would need to distinguish those transitions from first-time ICHRA adoption.
What the newer channel update adds
HealthSherpa reports 58% year-to-date growth in ICHRA enrollment flowing through its channel and 83% of that enrollment off-Exchange. Its exact post date was not displayed. Channel mix and an estimated national population remain different measures. source
A larger estimate later in the year could reflect real adoption, a broader definition, more complete observation or a different extrapolation. The reviewed evidence does not quantify each explanation. Selecting the largest number would conceal that uncertainty rather than resolve it.
The definitions a credible market table needs
Store the observation date, release date, unit, eligible population, collection method, contributors and treatment of duplicates with every number. “Employer” should specify active or historical accounts. “Member” should specify whether dependents are included. “Enrollment” should distinguish a selection from coverage that actually started.
CMS maintains a separate series for effectuated coverage. We located that series but did not extract a new numeric paid-enrollment total in this review. Its existence is another reason to preserve the “plan selections” label on the Marketplace figure. source
What would change this conclusion?
A reconciled dataset with shared definitions, documented deduplication and comparable time periods could support a stronger national estimate. Until then, we publish the figures with their boundaries. This is ICHRA Report’s analysis of external research; it is not a survey or market census we conducted.
Related reading: employer interest versus implementation and what contribution data can establish.
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.