ICHRA Newsletter

Week of December 8–14, 2025

Executive Summary

This week in ICHRA developments, amid rising ACA Marketplace premiums projected at a median 18% increase for 2026 and the uncertain extension of enhanced premium tax credits expiring at year-end, ICHRAs emerge as a flexible alternative for employers to control costs and provide personalized coverage. Legislative updates highlight the unlikely continuation of ACA subsidies, prompting states to bolster premium support and reinsurance, while employers face compliance tasks under the One Big Beautiful Bill Act. The HRA Council responded to a congressional RFI on ICHRA, advocating for regulatory fixes to enhance adoption. Discussions also focus on ICHRA's potential to favor narrow networks and address cost crises, though challenges like employee abrasion and fragmented care persist. Overall, ICHRA continues to gain traction as a strategic pivot for budget predictability in a volatile health benefits landscape.

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