Key Findings from Volume 4:

• Applicable large employers (ALEs with more than 50 FTEs) are choosing ICHRA: Aggregated ALE adoption is up 34%, with some large employer cohorts showing 49% year over year growth from 2024-2025.
• Small employers (fewer than 50 FTEs) are adopting ICHRA as well as QSEHRA: Small business, non-ALE ICHRA adoption is up 52% among HRAC Founding Members.
• QSEHRA and ICHRA continue to be an on-ramp to benefits for small employers: 83% of employers offering ICHRA or QSEHRA in 2025 had not previously offered any coverage, while 17% transitioned from traditional group insurance.
• Employees cover more dependents: The dependent coverage ratio has grown to .67, meaning employees find the options and choice of ACA-compliant coverage so valuable their families are choosing their favorite health insurance via ICHRA and QSEHRA.

Methodology:

This report is based on anonymized, record-level data voluntarily shared by eligible HRA Council Platform Members as of January 2025. It reflects actual ICHRA and QSEHRA adoption and enrollment for the 2025 benefit year—capturing both employer- and employee-level details—not survey responses or projections. Participating platforms submit data in a standard format, which is aggregated and analyzed to identify national trends using basic year-over-year comparisons and distribution analysis.