Key Findings from Volume 5:

• ICHRA adoption has increased significantly across all measures.
• ALE growth is exponential and brings experienced health consumers.
• This report observes a positive effect on the Marketplace based on employee demographics and plan selection behavior.
• As larger employers adopt ICHRA, this positive effect on ACA risk pools multiplies.

Methodology:

This report is based on anonymized, record-level data voluntarily shared by eligible HRA Council Platform Members as of January 2026. It reflects actual ICHRA and QSEHRA adoption and enrollment for the 2026 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.