Group premiums vs two ICHRA budgets
| Option | Per employee, per year | 25 employees, per year | Who sets the cost |
|---|---|---|---|
| Group plan, single coverage, employer share (firms with 10 to 199 workers, 2025) | About $7,737 (84% of a $9,211 premium) | About $193,425 | The insurer, at each renewal |
| Group plan, family coverage, employer share (firms with 10 to 199 workers, 2025) | About $17,165 ($26,054 premium minus $8,889 worker share) | Depends on how many choose family coverage | The insurer, at each renewal |
| ICHRA design A: $400 a month | Up to $4,800 | Up to $120,000 | The employer |
| ICHRA design B: $625 a month | Up to $7,500 | Up to $187,500 | The employer |
Two things the table can't show. An ICHRA is a reimbursement arrangement: you pay what employees claim for their premiums and eligible costs, up to the allowance. And real groups mix single and family coverage, so get a quote for your own census before comparing.
Example: a 25-person company compares costs
Say a company has 25 full-time employees, no group plan yet, and every employee would take single coverage. This is an illustration, not a quote or tax advice.
- Group benchmark: at KFF's 2025 small-firm averages, the employer's share of single coverage is about $7,737 a year per employee, or about $193,425 for 25 people.
- ICHRA design A: a $400 monthly allowance is $4,800 a year per employee, at most $120,000 for 25 people, about $73,425 less than the group benchmark.
- What an employee pays: a 40-year-old buying a plan at the 2026 average benchmark Silver premium of $625 a month pays $625 minus $400, or $225 a month, out of pocket after reimbursement (they can pay it pre-tax only for plans bought outside the Marketplace).
- Affordability for that employee: for 2026, HealthCare.gov counts the offer as affordable if the lowest-cost Silver self-only plan, minus the allowance, is under 9.96% of monthly household income. With household income of $48,000 ($4,000 a month), that's $398.40. The lowest-cost Silver plan costs no more than the benchmark, so the net is $225 or less: affordable. That employee can't get a premium tax credit.
- ICHRA design B: a $625 allowance would cost up to $187,500, close to the group benchmark, but the budget is fixed by the company, not by an insurer's renewal.
For plan years beginning in 2027, the IRS set the affordability percentage at 10.22% (Rev. Proc. 2026-26). For the step-by-step setup, notices and classes, see the ICHRA guide.
Payroll taxes and the employer mandate
- Payroll taxes: IRS Publication 15-B says employer payments and reimbursements of medical expenses under an accident or health plan, which includes an ICHRA, are excluded from wages and exempt from Social Security, Medicare and federal unemployment tax (2% S corporation shareholders are an exception). The same is true for an employer's share of group premiums. A taxable raise or stipend of the same amount would be wages, with payroll tax on top. See health insurance stipend.
- Fewer than 50 full-time employees (including equivalents): no employer mandate, so the ICHRA's size is a business choice. Affordability only decides whether employees can get a premium tax credit instead.
- 50 or more full-time employees: the employer mandate applies, and an ICHRA needs an amount that makes the offer affordable, tested against the lowest-cost Silver self-only plan. For 2027 plan years the percentage is 10.22%. The ICHRA guide covers the test; have a benefits advisor run your numbers.
- Age and family size: within a class, ICHRA amounts can rise with age (up to 3 to 1, oldest to youngest) and with the number of dependents, which matters because individual premiums rise with age.
Where a group plan can come out ahead
- The SHOP tax credit. HealthCare.gov says employers with fewer than 25 full-time equivalent employees, average salaries of about $65,000 or less, that pay at least 50% of full-time employees' premiums can get a credit worth up to 50% of premiums paid (35% for nonprofits). SHOP coverage is generally the only way to claim it, and it can't be combined with an ICHRA. A company with exactly 25 full-time employees is just over that line.
- Low-income employees. An affordable ICHRA offer blocks the premium tax credit, which for some lower-income employees would have been worth more than the allowance. See premium tax credit.
- One plan for everyone. A group plan gives every employee the same network and benefits. With an ICHRA, each person shops their local individual market, and choices vary by county.
- Your renewal is competitive. If a broker's group quote for your census comes in below the allowance you'd need, the group plan costs less. Compare real quotes, not averages.
KFF estimates that in 2025, 4% of firms offering health benefits, and 9% of firms that don't, gave one or more employees money to buy individual coverage. For other small-business options, see ICHRA vs QSEHRA, group health insurance and small business health insurance.
This is general information, not tax or legal advice. For plan design, ask a benefits attorney or tax advisor.
Ask Gabriel with your numbers
Gabriel can work through the same comparison with your own headcount, ages, ZIP codes and budget, free. Ask Gabriel free.
Employers with 25 or more employees can also add Gabriel for Teams, a care membership, alongside a health plan. It is not group health insurance and not an HRA or ICHRA, it doesn't replace a health plan, and it never satisfies the ACA employer mandate. Gabriel is not an insurer.
Common questions
Is an ICHRA cheaper than group health insurance?
It can be, because you set the allowance. In 2025, KFF estimates small-firm employers paid roughly $7,700 a year toward each worker's single group coverage; an ICHRA allowance of $400 a month is $4,800 a year. Whether it's cheaper for you depends on the allowance and your group quote.
What are the pros and cons of an ICHRA?
Pros: a fixed budget you control, tax-free reimbursements, and amounts that can vary by age and family size. Cons: employees shop the individual market on their own, an affordable offer blocks their premium tax credit, and it can't be paired with the SHOP tax credit.
Do employers pay payroll taxes on ICHRA reimbursements?
No. IRS Publication 15-B says reimbursements of medical expenses under an accident or health plan are exempt from Social Security, Medicare and federal unemployment tax, except for 2% S corporation shareholders.
How much should an employer put in an ICHRA?
There's no federal minimum or maximum. Large employers (50 or more full-time) need an amount that makes the offer affordable: for 2027, the lowest-cost Silver self-only plan minus the allowance must be under 10.22% of the employee's household income.
Can a small business get a tax credit with an ICHRA?
Not the Small Business Health Care Tax Credit. HealthCare.gov says SHOP coverage is generally the only way to get it, and an ICHRA can't be combined with SHOP.
Sources
- 2025 Employer Health Benefits Survey: Summary of Findings KFF
- Marketplace average benchmark premiums KFF
- CHOICE Arrangements (formerly individual coverage HRAs) HealthCare.gov
- Rev. Proc. 2026-26: 2027 required contribution percentage IRS
- Publication 15-B (2026): Employer's Tax Guide to Fringe Benefits IRS
- Small Business Health Care Tax Credit HealthCare.gov
This guide is general information, not medical advice. It does not replace a visit with a licensed clinician. Gabriel membership is not health insurance.