Credit: Adobe Stock
The rise of the market for individual coverage health reimbursement arrangements may be starting to revive sales of individual and family major medical coverage outside of the Affordable Care Act public exchange system.
Up-to-date figures for on-exchange and off-exchange individual coverage sales are hard to find, but Danielle Winiecki, an ICHRA broker engagement strategist at Centene's Ambetter Health Solutions division, said she thinks sales in the off-exchange market are much higher.
Ambetter has been one of the health insurers that has made a point of courting ICHRA plan sponsors and ICHRA plan participants.
"We estimate between 75% and 85% of ICHRA enrollments are off-exchange," Winiecki said.
For the typical ICHRA user, the off-exchange market is a better fit, Winiecki said.
One reason is that use of off-exchange market allows for more flexibility in terms of coverage design, and another reason is that federal income tax rules tend to favor use of off-exchange plans, she said.
Today, the federal tax rules let workers subtract some of the cash used to pay for off-exchange coverage from their taxable income. Workers cannot exclude the cash used to pay for ACA exchange plan coverage from their taxable income. The House included a provision that could have eliminated the distinction in the legislation that became the One Big Beautiful Bill Act. The provision dropped out of the package before final passage.
What it means: Managers of the ACA exchange program may need Congress to update the program rules to help them stay in the ICHRA game.
The backdrop: Policymakers created the qualified small employer HRA program in 2016 and the ICHRA program in 2019.
Both programs provide a legally recognized arrangement that employers can use to achieve a long-cherished goal: Handing employer cash to workers and letting the workers buy their own health coverage, without worries about health problems affecting either access to the coverage or the premiums.
The COVID-19 pandemic interrupted employers', health insurers' and plan administrators' efforts to get cash-for-coverage programs up and running.
The market woke up in 2023, expanded in 2024, and, according to Winiecki and other market observers, grew again in 2025.
Performance: Hard ICHRA enrollment numbers are still scarce.
Public companies that occasionally give hints about ICHRA performance include Centene, which lumps ICHRA enrollment together with commercial group plan enrollment and non-ICHRA individual coverage sales; Oscar Health; and brokers, including eHealth and Willis Towers Watson.
Ambetter has seen "steady, year-over-year growth" in ICHRA sales, growing broker familiarity with ICHRAs and growing employer confidence in ICHRAs, Winiecki said.
She sees higher attendance at ICHRA-focused events and webinars as evidence that sales will continue to grow.
Because only small employers can use QSEHRA plans, "QSEHRA remains a more limited solution," Winiecki said.
© Arc, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to TMSalesOperations@arc-network.com. For more information visit Asset & Logo Licensing.