The number of people covered by individual coverage health reimbursement arrangements doubled year over year and surpassed 500,000 at the start of 2026, driven largely by a surge in adoption among larger employers, according to the HRA Council’s fifth annual report on the state of the ICHRA and QSEHRA markets.

The Aug. 12 report includes information from 17 companies and covers more than 200,000 enrollment records across all 50 states, with the council estimating that its data now represents 75% to 80% of total ICHRA market activity. The report found that ICHRA’s growth trajectory held even as the ACA marketplace faced stress from the expiration of enhanced premium tax credits and rising monthly premiums heading into the 2026 plan year.

Read the full story here: https://www.beckerspayer.com/payer/ichra/ichra-market-doubles-to-500000-enrollees-report/

As U.S. employers brace for the largest price hikes on employee health plans in 15 years, a growing number are opting out of group insurance altogether.

Instead of providing medical benefits directly, more than 20,000 companies entered Health Reimbursement Arrangements (HRA) in 2026. That’s an increase of 53% from last year, according to a new report by advocacy group the HRA Council.

Read the full story here: https://www.fa-mag.com/news/u-s--employers-abandon-group-health-insurance-as-price-hikes-bite-88078.html

HRA Council 2026 Board Elections

Member Announcement

Dear Members,

Thank you for your commitment to educating, growing, and shaping our industry. Every year we hold Board elections for three-year terms for members who are eligible to serve on the Board.

We encourage every full member in good standing to consider running for the Board. Here is what to know and how to nominate yourself or a colleague.

Nomination Deadline: July 24, 2026
Election Period: July 27 – August 7, 2026 

Seats Available

Five (5) seats on the 12-member Board are open for election, each for an initial three-year term:

• 3 General seats — open to all eligible members in good standing.
• 2 Role-specific seats for members with relevant professional background:

◦ Volunteer General Counsel or notable experience in legal and compliance with direct access to internal General Counsel when needed. (This role encompasses general board service with expertise to be requested as and when needed)

◦ Volunteer Board member with notable experience in Finance and GAAP with access to tax and finance expertise when needed. (This role encompasses general board service with expertise to be requested as and when needed)

Member organizations will be asked to affirm that if a person elected to a role-specific seat becomes unavailable, the organization will nominate a representative with similar qualifications.

Note: Seven (7) of the 12 Board seats remain filled by current members. The five open seats are the only ones up for election. Current Board members eligible to run again for an additional term: Oscar, W3LL, Gravie.

How to Nominate

Email info@HRACouncil.org no later than July 24, 2026 with the following:

• Name
• Organization
• Title
• Brief statement of why you wish to serve / why you are a strong candidate
• Recent photo

Important: If your current role is not C-Suite or an equivalent senior executive position, please cc: the head of your organization in your nomination email. This confirms they understand the requirements of Board service and that your organization will support the educational mission and growth of HRA Council.

General Qualifications

Who qualifies?

• Members in good standing with dues paid/renewed, reflecting at least one (1) year of full organizational membership prior to standing for election.

◦ Generally, in addition to the organizational membership qualifications, persons being submitted for consideration should be in their current roles at least 6 months prior to nomination.

◦ Exceptions to these 1-year and 6-month policies are rare but exist and might include examples as follows: when a human representative changes roles or organizations within a longer membership arc, or when a lapsed organization rejoins and is continuing a larger overall commitment.

• Board members must be able to speak for their organization and commit organizational resources: time, expertise, financial support, team members, and more.

• CEOs, C-Suite, Presidents, Vice-Presidents, SVPs, Director, General Manager, and equivalent titles carry the expectation that you can commit your organization to support various initiatives.

What if I don't have a C-Suite title?

You may still be eligible. A role such as "Head of ICHRA" or similar can be the right fit.

In these cases:

• Include your CEO or another senior executive on your nomination email to info@HRACouncil.org.

• This allows your organization to affirm support and confirm succession: if you move to another company or retire, the CEO would fill your former seat and potentially nominate another qualified candidate.

Do I personally own my Board seat?

No. While individual leaders run for the Board, HRA Council bylaws designate Board seats as belonging to the organization, not to the individual. This ensures continuity for both the Council and the organization's commitment.

Background

HRA Council membership has doubled in the last two years, encompassing new members in a variety of categories. In recognition of our growing industry reach and diversity, we are opening the full complement of 12 Board seats for the first time, including two seats designated for members with specific legal and financial backgrounds.

The schedule for the remaining Board seats are as follows:

● Up for Election in Summer 2027 – Health One Alliance, Capitol Blue, Remodel Health

● Up for Election in Summer 2028 – zizzl, Health Sherpa, Take Command Health, Kelly Specialty Group

● Up for Election in Summer 2029 – the Board members you elect this summer in 2026

We look forward to your nominations and to welcoming new leaders to the Board.

Questions? Contact us at info@HRACouncil.org.

Warm regards,

HRA Council

Healthcare costs are hitting small and mid-sized employers from multiple directions at once. Individual market premiums have climbed more than 20% nationally, according to Thatch’s 2026 Health Benefits Outlook. And Mercer reports total health benefit cost per employee is projected to rise 6.7% in 2026, the highest increase in roughly 15 years.

Just as each renewal season is different, employees are expecting more flexibility in how coverage is delivered. For employers that need both predictable costs and a competitive benefits package, Individual Coverage Health Reimbursement Arrangements, or ICHRAs, are quickly becoming part of the answer.

Read the full article here: https://hrexecutive.com/5-reasons-small-businesses-should-consider-ichras-for-health-benefits/

Congratulations to Arizona Gov. Katie Hobbs, State Rep. David Livingston, the Arizona state legislature, and all of our members who supported House Bill 2693, which instructs the Arizona Department of Administration to conduct a feasibility study for individual coverage health reimbursement arrangements. 

The bill was signed into law June 4, 2026, and is anticipated to result in guidance for ICHRA as a solution for state employees. This innovative and practical approach gives a strong signal to Arizona businesses as well as municipalities and organizations nationwide, that ICHRA can be a game-changing benefit for diverse local, regional, and national employee groups. 

Leadership from HRA Council member Brooke Tiner, with Oscar Health, is noted in the story. 

https://www.beckerspayer.com/payer/ichra/could-arizona-swap-traditional-state-employee-health-plans-for-ichras/?origin=PayerE&utm_source=PayerE&utm_medium=email&utm_content=newsletter&oly_enc_id=5977F1087134B7Z

The Centers for Medicare & Medicaid Services, Department of Health and Human Services, posted a proposed rule to the Federal Register: CMS-9883-P.  

Long title: Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program

We refer to it as the NBPP for 2027 and have submitted comments on Marketplace stability, innovation, and consumer choice in our comment letter, attached here as a PDF.  CMS-9883-P NBPP Comment Letter HRAC.pdf

HRA Council members are encouraged to submit their own responses, including using ours as appropriate. 

Portable benefits are moving from policy discussion to workforce expectation. Employees increasingly want coverage they can keep when switching jobs, pushing employers to rethink how benefits are structured and delivered.

Robin Paoli, Executive Director of the HRA Council, a non-partisan advocacy group focused on health reimbursement arrangements and employer-sponsored coverage, says portability reflects a shift toward benefits that function more like consumer products. "One of the trends is self-owned, portable benefits that travel with us in the same way our cell phone numbers do. More people want that for their benefits," she says.

Read the full story here: 
https://www.benefitsbriefnews.com/news/portable-employee-benefits-robin-paoli-hra-council?utm_campaign=51134316-Benefits%20Brief&utm_source=linkedin&utm_medium=paidsocial

In April 2025, the HRA Council submitted an official response to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rule titled “2025 Marketplace Integrity and Affordability Proposed Rule” (CMS-9884-P). This proposed rule would introduce several regulatory changes to the operation of the individual market, including elements with potential implications for employers and employees using ICHRAs and QSEHRAs to access health coverage.

The Council’s letter, submitted via Regulations.gov, aims to ensure that the growing ICHRA ecosystem—which now includes large and small employers, brokers, TPAs, and digital health insurance platforms—can continue to thrive under policies that safeguard both integrity and access.

This official comment letter was crafted with input from HRA Council leadership and members, and reflects deep industry experience across all 50 states. It underscores the importance of preserving ICHRA and QSEHRA accessibility, efficiency, and affordability amid regulatory changes.

Here are some key takeaways from our response:

• ICHRA continues to work successfully as a modern alternative to group coverage with strong adoption across employer sizes, and more than 600% growth since its inception.
• Proposed regulatory changes could create unintended consequences such as administrative burden, employee confusion, and barriers to effectuation—particularly regarding shortened Open Enrollment Periods, premium payment windows, and new verification rules for SEP eligibility.
• The Council recommends deferring some implementation timelines (e.g., OEP changes) to 2027, to allow for proper operational updates and employee onboarding.
• The Council urges CMS to consider exemptions or tailored compliance measures for ICHRA/QSEHRA enrollees, given their inherently lower fraud risk and employer-directed nature.
• Stability in individual market tax credits is essential to support robust plan options for employees using ICHRA, especially as employers shift from group to defined contribution models.
• Employers must be protected from liability linked to employee past-due premiums, which could otherwise threaten their ability to offer health benefits through ICHRAs.
• We appreciate CMS's commitment to integrity and look forward to continued dialogue to ensure these important innovations in employer-sponsored insurance remain a viable, growing option for America's workforce.

Click here to read the full letter.

ICHRA was prioritized by the US House Ways and Means Committee, the House committee of jurisdiction for health reimbursement arrangements, at the end of 2024. In December, the HRA Council and other stakeholders received a public Request for Information (RFI) on ICHRA from the office of Rep. Kevin Hern (R-OK), Ways and Means Committee Member and sponsor of the 2023 CHOICE Arrangement Act, ultimately sent back to Committee, which sought to establish statutory authority over ICHRA and other alternative health insurance options for employers. The Council responded to the RFI and is now making the full text of our response available to the public.

This official HRA Council response was developed through close collaboration among our leadership and Members. We believe it represents the best interests of the widest set of health insurance stakeholders, including those employers, health insurance professionals, and US workers who remain unaware of ICHRA's growth, advantages, or even existence.

Here are some key takeaways from our response:

• ICHRA is in great working order as a proven, increasingly popular solution to known challenges in the Employer-Sponsored Health Insurance markets;
• A small set of specific process and regulatory fixes would further reduce the administrative, cost, and change management burdens or disparities in providing ICHRA as a health benefit, while improving the Employer and Employee experience;
• As a Council, we support further consideration of provisions to allow for Employers to offer both traditional group coverage and ICHRA to their entire workforce, further expanding flexibility and choice for both Employers and Employees, already hallmarks of ICHRA as a health benefit option;
• Much more awareness and education should be propagated by the Tri-Agencies overseeing ICHRA, on par with the resources made available to Employers and Employees for understanding other Employer-sponsored benefits.

Click here or the link in the "Comment Letters" section of hracouncil.org/action to see our full response.

For questions, please email robin@hracouncil.org.

Supporting ICHRA Education in Colorado

The HRA Council was honored to be invited by Connect for Health Colorado (C4HC), the Colorado state-based exchange, to provide ICHRA education and updates during C4HC’s pre-open enrollment conference for brokers: CoverCO 2024.

CoverCO organizers asked us to be creative and engaging, so we worked with members to create a “quiz show” feature for the first half of our morning panel on ICHRA 101+.

More than 100 participants, mostly brokers, joined our ICHRA 101+ panel with its fast-paced quiz show format. During the second half of the morning panel, we segued to a live Q&A session. 

The second panel featured an insightful conversation about how defined contribution health coverage is bringing changes to the individual and group markets. “What’s next for ICHRA and Beyond!” also had a great turn-out of broker attendees plus a lively Q&A session that addressed questions ranging from which industries are particularly well-suited for ICHRA, to how to help a company with remote workers in multiple states. 

Thanks to our members and staff for providing top-notch educational resources, and much gratitude to C4HC for inviting us. Learn more about the panels and panelists, below.

Panel 1:  ICHRA 101+

Did you know Colorado is a Top Ten state for ICHRA? Learn with our experts in a fast-paced, dynamic session about ICHRA, the innovative employer-sponsored coverage option that empowers employees to select ACA-compliant plans on- and off-exchange. The HRA Council is an expert ecosystem of carriers, administrators, brokers, health wallets, legal and compliance specialists, and enrollment technology platforms. Moderator: Robin Paoli, Executive Director, The HRA Council

• Libby Hart, Capital Blue
• Tom Crennan, Colorado Health
  
• Jared Dodds, TakeCommand Health
  
• Henry von Hagke, Zizzl

Panel 2:  What’s next for ICHRA and Beyond! 

ICHRA and QSEHRA have been game changers for employers wanting to provide a spectrum of health and wellness benefits to their employees. Learn what changes are coming to plans, products, and benefits, from national experts. Moderator: Robin Paoli, Executive Director, The HRA Council

• Eric Allen, FlyteHCM
  
• Libby Hart, Capital Blue
  
• Michelle Mead, Leeway
  
• Andrew Reeves, gravie

C4HC recorded our sessions and posted the videos and slide decks as educational resources for all CoverCO 2024 participants.