Harvard professor and physician Benjamin D. Sommers, MD, PhD, is a health policy researcher who wrote about ICHRAs (including the HRA Council Data Report) in the JAMA Health Forum this summer: 

https://jamanetwork.com/journals/jama-health-forum/fullarticle/2821807

Dr. Sommers is an independent researcher and his article is examines ICHRA from a variety of viewpoints. We've excerpted two sections, below, that are of particular interest to HRA Council Members.

Here's a brief excerpt: 

"The main potential advantage of the HRA model is that it may offer employers and employees more flexibility. Employers can set a fixed dollar amount instead of having to shop for and purchase insurance. This may induce some small employers to participate who might otherwise not offer health benefits, or who would feel the need to cut benefits in times of rapid premium growth. Health reimbursement arrangements may also enable firms with remote workers across state lines to offer meaningful health benefits because employees can use HRAs to obtain coverage wherever they live. In addition, an HRA gives employees many more plan options than they would typically get, especially from small employers."

"Depending on the evidence that emerges, 2 potential policy improvements could include (1) allowing workers who receive HRA contributions from employers to remain eligible for Marketplace subsidies, offset by the amount of the HRA; and (2) revising the tax code to allow workers who use HRAs to buy Marketplace insurance to deduct their share of the premiums from their taxable income (currently this is only permitted when using HRAs for non-Marketplace coverage). These changes might represent a best of both worlds approach, combining flexibility and affordability."