After a year defined by premium pressure and plenty of noise about the future of the individual market, 2026 is starting to look less like a question mark and more like a turning point for ICHRA.
The biggest shift? It’s no longer whether ICHRA “works.” It’s now that more employers, brokers, and carriers are treating ICHRA as a long-term benefits strategy — supported by stronger off-exchange products, better infrastructure, and improving decision support.
So what comes next for ICHRA in 2026? In our recent webinar with Employee Benefit News, we assembled a group of ICHRA experts to unpack what’s happening, share predictions, and advise on how benefits pros can respond.
Watch the webinar recording here, and read on for the key takeaways.
Plot twist: ICHRA is showing increased momentum in 2026 (even after subsidy uncertainty.)
When enhanced premium tax credits expired, many expected the individual market to crash — driving fewer plan choices, more volatility, and a slower runway for ICHRA.
So is ICHRA now dead? Not at all. Instead, early signals in 2026 point to resilience and continued momentum.
As Alan Silver, President of ICHRA at Ambetter Health Solutions, put it, “If ICHRA were dead, I would’ve been concerned about whether or not I was going to retain the population that we had on ICHRA, as opposed to grow it by more than twofold.”
Silver emphasized specific momentum across off-exchange purchasing (a key arena for ICHRA): “Off exchange purchasing in 2026 increased by quite a lot. More than double.”
The takeaway going into 2026: Policy shifts matter, but the speed of adoption is being driven by structural problems in group coverage (cost volatility, administrative burden) and structural improvements in ICHRA execution (technology, product design, and decision support).
The employers who get the most value from ICHRA treat it like a strategic planning decision, not a renewal reaction.
In previous years, ICHRA was often introduced during renewal season as a last-minute escape hatch: “The renewal came in at +40% and everyone panicked.” But that’s changing.
Sam McIntyre, Client Executive at M3 Insurance, described the evolution: “Historically it was a very reactive conversation happening in the 11th hour… Your renewal comes out, ‘Oh, we can’t take this. Let’s get that ICHRA thing.’”
This year, he expects ICHRA decisions to be made more upstream — before renewal season forces a rushed call. In McIntyre’s words: ‘If you are reaching out to me in October, it’s probably too late.’”
The takeaway going into 2026: Treat ICHRA evaluation like a proactive benefits planning motion, not a reactive scramble.
The mid-market is hitting a breaking point, especially on family premiums
One of the sharper near-term forecasts from the discussion: mid-market employers (roughly 100–1,000 lives) are likely to see family premiums become increasingly untenable.
McIntyre’s near-term prediction: mid-market employers could see family premiums “potentially eclipsing… $35,000 annually.” A hot take? Yes. Will it pan out? TBD (but it doesn’t look good.)
He also predicted a “quiet repricing” dynamic in the group market — a kind of slow-motion destabilization as more employers adopt alternatives (self-funded, captives, direct contracting, carve-outs, ICHRA).
The takeaway going into 2026: If you advise (or operate) in the mid-market, treat 2026 as the year to model scenarios — not just renew. Defined contribution strategies (ICHRA and adjacent designs) become less “experimental” and more “necessary” when volatility pushes past tolerance.
The “healthcare wallet” is becoming the north star — and ICHRA is an early version of it.
One major signal heading into 2026 is the growing appetite — across employers and policymakers — for models that put more healthcare dollars directly into employees’ wallets.
ICHRA already operates in that direction by funding coverage through a defined contribution. But Silver offered an important forecast: “The way ICHRA is today is not the way that ICHRA is going to look in five to 10 years.”
Today, many employers still view ICHRA primarily as a way to fund premiums. But the longer-term trajectory is broader: a true ‘healthcare wallet’ that lets people allocate dollars across coverage and care.
The takeaway going into 2026: Education and guidance have become a must-have. As choice expands, successful employers will pair defined contribution with decision support and care navigation so employees can allocate dollars confidently.
Stop trying to recreate group insurance. Product design will follow what employee populations actually need — and choose.
Silver put it plainly: “We aren’t trying to replicate group [on the individual market with ICHRA]… We’re trying to deliver something different.”
This shows up in the perennial PPO question. Employers and brokers often cite the lack of PPO networks on the individual market as a deficiency because they equate PPO with “good coverage.”
But employee purchase behavior doesn’t always match the assumption, Silver explained: “We did [PPOs] in 2025. We did for 2026. Guess what? People didn’t buy PPOs.”
Why? Because what employees value is personal — network access, specific facilities, premium vs deductible tradeoffs, and their own utilization expectations. “Each one of us needs our own network to navigate.”
And that’s where off-exchange innovation is headed. Silver described what will be built for ICHRA-aligned demand: “You’ll see things like broader networks… you’ll see condition-specific plans… partnership plans with health systems… adding on some point solutions that may help with GLP-1 navigation.”
The takeaway going into 2026: Expect more sophisticated off-exchange offerings designed around employee populations, not around copying group plan templates.
ICHRA infrastructure is improving… and it’s quickly becoming the deciding factor.
Even if the strategy is sound, execution still makes or breaks ICHRA. One friction point is unavoidable: ICHRA enrollment entails many individual applications rather than one group app.
From the carrier side, Silver highlighted the fix: “Technology, APIs, connectivity to ICHRA administrators… improving our technological systems to allow for the fact that we are going to have group purchasing of our products by employers.”
He also called out the operational gap the industry must close: “We cannot be regimented around an individual paying a binder payment with an application… the payment for them, that’s a different story. And the bulk acceptance, that’s a different story.”
The takeaway going into 2026: The carriers and platform ecosystems that improve payment flows, enrollment handoffs between platforms and carriers, and data connectivity will accelerate adoption — because they remove the last mile friction that creates bad first impressions.
The old assumption is breaking: employees can choose plans (with the right support.)
One of the most actionable signals from the conversation: employees can handle plan choice when the experience is designed well.
Ben Light noted the shift from 2019 skepticism to today’s reality: “Only 15% [of 2026 enrollees] actually needed a live phone call… which means 85% of people were able to use our tools and use the decision support tool and pick their own plan.”
That matters because the healthcare wallet trend depends on exactly this capability: giving people resources to allocate dollars in a way that matches their lives.
The takeaway going into 2026: Stop designing around the fear that employees can’t handle choice. Design around enabling choice: decision support + clear comparisons + a human backstop.
So what next? Here’s your 2026-ready checklist.
For employers
- Pressure-test the operational upside of your benefits strategy. If you’re tired of volatile renewals and plan complexity, you’re not alone. Many employers are realizing they don’t want to devote their HR team’s time “being in the health insurance game.” If your team is exhausted by claims reviews, renewals, and vendor sprawl, ICHRA can shift you toward a set-it-and-fund-it model.
- Evaluate fit using two practical lenses: workforce geography and population makeup (hourly vs salaried dynamics).
- Design for consumer behavior (the actual kind, not just what’s always been done.) If you move to defined contribution, pair it with decision support and education so the model actually works at scale.
For brokers/advisors
- Start earlier than renewal season. Make ICHRA part of the strategic planning calendar, not just the “break glass” option.
- Lean into the advisory role. As McIntyre framed it: clients aren’t asking brokers to “quote insurance”—they want consultation, strategy, and help navigating complexity.
- Bring ICHRA to the table. As Ben Light, VP of Partnerships at Zorro, put it, “If you’re not talking to your clients about ICHRA, somebody else is.”
Curious about ICHRA? We can help pressure-test it for your 2026 strategy.
Whether you’re advising clients, building partnerships, or evaluating options for your own organization, we’re happy to talk through fit, timelines, and what “good execution” looks like. Reach out to schedule a quick ICHRA strategy conversation.
