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Market measurement

How many people use ICHRA? What the 2026 evidence can tell us

How many people use ICHRA depends on what a source counts. Compare employer offers, enrolled workers, estimated covered lives and the wider individual market, including the new Census coverage report and the federal MEPS questions.

Research conclusion

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 measureReported valueBoundary
HRA Council: known participating employees261,000January 2026; page 8
HRA Council: covered lives402,000Derived using a 1.54 dependent factor; not a direct count of unique member records
HRA Council: broader covered-life estimate500,000+Includes an allowance for coverage outside its contributors
HealthSherpa: national market estimateAbove 1 million membersCompany estimate in a mid-year update; not its own enrollment count
CMS: 2026 Marketplace selections23.1 millionWider 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

Does 10.5% direct-purchase coverage mean 10.5% use ICHRA?

No. Census's September 15, 2026 release, Health Insurance Coverage in the United States: 2025, reports direct-purchase coverage for 10.5% of the population during 2025. That category describes individual insurance obtained from an insurer or an exchange. It is not a count of people receiving ICHRA reimbursements. source source

Keep two questions separate: where did the insurance policy come from? and how was the premium financed? An ICHRA can help pay for an individual policy, but the broad direct-purchase category does not isolate that financing arrangement. It includes people whose premiums are funded in other ways. The aggregate percentage does not establish ICHRA enrollment, employer contributions or ICHRA growth.

The report measures coverage during a calendar year. People can appear in more than one coverage category, so categories must not be added as if they were mutually exclusive market shares. Nor should an annual coverage measure be compared directly with a single month's enrollment. These are national coverage statistics, not local premium or carrier-availability data. source

Does the government ask employers specifically about ICHRA?

Yes. Question 21 of the 2025 MEPS Insurance Component establishment questionnaire separately identifies an ICHRA offer, a QSEHRA offer, neither, or an unknown answer. Its instructions distinguish these arrangements from traditional HRAs. That is evidence that the instrument asks the relevant offer question; it is not an adoption estimate. source

The corresponding plan questionnaire's Question 22 asks about traditional HRAs and excludes ICHRA and QSEHRA. This distinction matters when reading a study labeled simply “HRA”: establish which arrangement it measured before applying its findings to ICHRA. See our HRA foundations for the relationship between the categories. source

To publish an employer-offer rate, we would need a verified weighted result, its survey population, denominator and uncertainty. Establishments and firms are not interchangeable; the form generally asks about the specified location. An offer also does not show how many eligible workers enrolled, received reimbursements or covered dependents. source

Current boundary: we verified the questions but have not verified a published weighted ICHRA/QSEHRA estimate from them. AHRQ states that MEPS-IC data files are not public because of confidentiality; approved research access is a separate process. Published tables must be checked before proposing any independent estimate. This is a research path, not a dataset we have already analyzed. source

Which number answers your question?

Define the unit before comparing adoption claims
QuestionRequired measureCommon substitution to avoid
How many businesses offer ICHRA?Firms or establishments offering it, with the unit explicit.Administrator accounts, survey interest or all HRA offers.
How many workers participate?Enrolled workers for a defined period, with duplicates addressed.Workers eligible for an offer.
How many people are covered?Workers plus covered dependents; identify counts versus estimates.A dependent multiplier presented as an observed headcount.
How large is the underlying insurance market?Individual coverage or Marketplace measures with dates and definitions.Direct-purchase coverage presented as ICHRA enrollment.

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

1
HRA Council — Growth Trends for ICHRA & QSEHRA, Volume FiveFull 14-page report reviewed, including tables on pages 6, 8–10 and methodology on page 13. January 31 observation date; contributed records, estimated covered lives, and matched-cohort growth have different denominators.Source reviewed 2026-09-11
2
HealthSherpa for ICHRA — 2026 ICHRA mid-year updateCompany-channel post reports 58% year-to-date enrollment-flow growth and an estimated national market above one million members. Exact publication date was not displayed; estimate is not a census.Source reviewed 2026-09-11
3
Centers for Medicare & Medicaid Services — 2026 Marketplace Open Enrollment ReportReports 23.1 million Marketplace plan selections or automatic re-enrollments during the 2026 open enrollment period.Source reviewed 2026-08-16
4
CMS — Marketplace effectuated enrollment data seriesData catalog distinguishes annual and monthly effectuated enrollment. No current numeric count extracted; 2026 plan selections must not be relabeled paid coverage.Source reviewed 2026-09-11
5
U.S. Census Bureau — Health Insurance Coverage in the United States: 20252025 coverage measured by 2026 CPS ASEC. Direct-purchase coverage is not ICHRA enrollment; annual categories can overlap.Source reviewed 2026-09-19
6
U.S. Census Bureau — CPS health insurance coverage estimates and definitionsDirect-purchase coverage definition; the aggregate category does not isolate ICHRA financing.Source reviewed 2026-09-19
7
AHRQ / U.S. Census Bureau — 2025 MEPS Insurance Component establishment questionnaire, Form MEPS-10Question 21 separates ICHRA and QSEHRA offers from traditional HRAs. Questionnaire is not a weighted estimate. Private-sector establishment classification confirmed through the survey questionnaire directory; HTML title has an inconsistent Government label.Source reviewed 2026-09-19
8
AHRQ / U.S. Census Bureau — 2025 MEPS Insurance Component plan questionnaire, Form MEPS-10(S)Question 22 excludes ICHRA and QSEHRA from the traditional HRA item. Instrument, not an adoption result.Source reviewed 2026-09-19
9
AHRQ — MEPS Insurance Component overview and data accessMEPS-IC data files are not publicly released because of confidentiality; approved research access is distinct from published tables. No weighted ICHRA estimate verified in this review.Source reviewed 2026-09-19

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.