ICHRA in Florida 2026: Why Zero Counties Qualify

Does ICHRA beat small group in Florida?

No, not currently, and we think that answer is more useful to a Florida employer than a rounded-up "it depends." An ICHRA (Individual Coverage Health Reimbursement Arrangement) lets an employer set a fixed monthly contribution and let each employee buy their own individual-market plan with it, tax-free. The arrangement only produces a cash saving over small-group coverage when the individual-market premium in an employee's county runs below the small-group premium for a comparable plan. Across Florida's 67 counties, our 2026 dataset does not show that condition anywhere. That is a real, checkable result, not a hedge, and it puts Florida in a different category from the two other state pieces we've published in this series: Texas, where 2 of 254 counties qualify, and Georgia, where 130 of 159 counties qualify.

That is not the same as saying ICHRA "doesn't work" in Florida, and we spend the second half of this article on why. But if you came here to find out whether the county math favors ICHRA over small group for a Florida workforce in 2026, the honest answer is no, and the rest of this piece explains exactly why, using Florida's own insurance-regulator filings.

If you run a company anywhere in Florida, from the Panhandle to the Keys, and someone suggested ICHRA might cut your benefits cost, this is the article that tells you whether that's currently true. It isn't, on the rate spread, and we'd rather tell you that directly than build a page that buries a "well, it's complicated" three thousand words down. What follows is the data behind that answer, what changed to produce it, and the separate, legitimate reasons an ICHRA can still be worth setting up in Florida even without a rate saving attached to it.

Florida's ACA marketplace in 2026

Florida runs its individual market through HealthCare.gov rather than a state-based exchange, and it remains the largest single ACA marketplace in the country. According to Florida Office of Insurance Regulation (FLOIR) rate filings for the 2026 plan year, 18 companies filed individual-market PPACA rates for 2026, including Cigna Healthcare of Florida and Ambetter Health of Florida entering as new carriers and Community Care Network filing new forms; separately, healthinsurance.org's tracking of Florida marketplace enrollment put 2026 plan selections at 4,538,772, down from 4,735,415 in 2025, a roughly 4% decline and the state's first enrollment drop since 2018.

The national backdrop is the same one driving nearly every ICHRA conversation right now: the enhanced ACA premium tax credits that Congress passed in 2021 and extended through 2025 expired on December 31, 2025, and were not renewed. A premium tax credit is a federal subsidy that reduces what a marketplace enrollee pays out of pocket each month, calculated on a sliding scale tied to household income; the enhanced version removed the old income ceiling on that subsidy for five years, and its expiration is what restored the 400% FPL cliff explained in the next section. According to KFF's tracking of the 2026 open enrollment period, national marketplace plan selections fell from about 24.1 million in 2025 to 23.1 million for 2026, the sharpest single-year drop since the ACA marketplaces launched. The average net monthly premium actually paid by an enrollee, after any tax credit, rose from $113 to $178, a 58% increase, and the average deductible rose from $2,759 to $3,786, a 37% increase KFF described as the steepest on record. The share of enrollees receiving any tax credit fell from 92% to 87%.

Florida enrollees felt that shift in concrete dollar terms. healthinsurance.org's Florida marketplace guide walked through two illustrative Fort Lauderdale examples built from filed 2026 rates: a 40-year-old earning $40,000 a year saw a net premium rise from about $34 a month in 2025 to about $110 a month in 2026, while a 60-year-old earning $63,000 a year, a household income near the upper end of subsidy eligibility, saw a net premium jump from about $191 a month to about $1,064 a month. That second example is what a cliff looks like in practice: a relatively modest income difference between two hypothetical enrollees produces a wildly different subsidy outcome, because one of them is still comfortably under 400% FPL and the other is close enough to the line that a smaller credit, or none at all, changes the math completely.

Insurer participation moved too. KFF's separate analysis of 2026 insurer participation found the national average number of marketplace insurers per state fell from 9.6 to 9.0, the first decline since the enhanced credits were introduced in 2021, and the number of counties served by only one marketplace carrier rose from 93 to 165 nationally. KFF attributes part of that contraction to Aetna CVS Health's exit from 17 states following the credit expiration. Florida did not lose its broad carrier base the way some states did; FLOIR's filings still show 18 companies active or entering the individual market for 2026. The story in Florida is less about carriers leaving and more about what happened to the prices those carriers filed.

The subsidy cliff, in dollars

"The subsidy cliff" describes what happens at 400% of the federal poverty level (FPL), the income line above which a household's premium tax credit eligibility used to disappear entirely. From 2021 through 2025, the enhanced credits removed that cap, so nobody lost their whole subsidy just for earning more; the credit simply shrank gradually as income rose. That cap returned for 2026 coverage, and it is a true cliff rather than a phase-out: cross the line by one dollar and the household's premium tax credit drops to zero for the year, all at once.

Premium tax credit eligibility for 2026 coverage is measured against the 2025 federal poverty guidelines, published by HHS in the Federal Register on January 17, 2025 (HHS publishes the guidelines about a year ahead of the coverage year they govern). At 100% of the 2025 guideline, a single person's threshold is $15,650 and a family of four's is $32,150, for the 48 contiguous states and DC. Multiply by four and here is where the 2026 cliff sits by household size:

Nationally, KFF found that households between 400% and 500% FPL made up only about 3% of 2025 marketplace plan selections, but accounted for 27% of the total enrollment decline heading into 2026, a 44% drop within that income band alone, or more than 321,000 people. That is exactly the income range where a well-paid employee at a small Florida business, someone who bought their own individual plan and claimed a subsidy for it, now finds themselves with no federal help at all if household income crosses the line.

Why individual coverage got pricier than group in Florida

This is the part of the Florida story that most 2026 coverage skips, because it requires looking past enrollment headlines into the actual rate filings. FLOIR requires every carrier writing ACA business in Florida to file its proposed rate change and the resulting weighted statewide average, separately for the individual and small-group markets. The two 2026 filings tell a very specific story.

In 2025, Florida's individual market averaged $648 a month against a small-group average of $728, meaning individual coverage ran about $80 a month cheaper, the direction that produces ICHRA savings. For 2026, individual coverage rose 34.1% to $867 a month, while small group rose a much smaller 12.8% to $821. The two lines crossed: individual coverage is now $46 a month more expensive than small group, on a statewide weighted-average basis. That's a swing of $126 a month, or roughly $1,512 a year, in a single plan-year rate cycle.

The mechanism is straightforward once you separate the two markets. Small-group premiums are community-rated across an employer's enrolled group and never touched a premium tax credit in the first place, so the credit expiration didn't move small-group pricing directly. Individual-market premiums absorbed the shock in two ways at once: carriers raised gross rates to cover a smaller, possibly higher-risk remaining pool as price-sensitive healthy enrollees left the market, and every dollar of that increase now lands on the enrollee directly for anyone who lost their credit at the 400% FPL line. Florida, with the largest individual marketplace in the country and a large share of enrollees near that income threshold, felt more of that shock in raw dollars than almost any other state.

There's a second, slower-moving factor layered on top of the subsidy shock: adverse selection. When roughly 4% of a market's enrollees leave in a single year, the ones most likely to drop coverage tend to be healthier people for whom a plan just became unaffordable without a subsidy, not people with ongoing medical needs who can't easily go without insurance. That shifts the average risk of everyone who remains upward, and carriers price the following year's rates against that remaining pool, not the one that existed before the exit. Small-group risk pools didn't see a comparable exit, because group enrollment isn't optional in the same way for most employees, so they didn't pick up the same compounding effect on top of the initial rate filing.

How Florida compares to Texas and Georgia

We've now published county-level ICHRA math for three states, and reading them side by side is more informative than any single one alone. Texas has the most marketplace carrier competition in the country, and that same dynamic that keeps individual pricing low in most Texas counties still only produces 2 qualifying counties out of 254, because Texas's small-group market is also unusually competitive. Georgia splits cleanly by geography: 130 of 159 counties qualify, almost everywhere except the deep-carrier-bench Atlanta metro, because rural and mid-size-metro Georgia counties have thinner individual-market competition that widens the spread. Florida is neither pattern. It isn't a state where some counties qualify and others don't depending on local carrier depth, it's a state where a single, large, statewide rate event, the individual market absorbing most of the subsidy-cliff shock while the small-group market barely moved, pushed every county the same direction at once.

That distinction matters for how you read any "ICHRA in [state]" claim, including ours. A county-by-county split like Georgia's tells you the answer depends on where your employees live. A statewide flip like Florida's tells you the answer depends on the calendar, specifically, on which plan year's rate filings you're looking at. Florida employers have more reason than Texas or Georgia employers to recheck this analysis every single renewal, because the entire 2026 result rests on one year's unusually large divergence between two markets that don't always move at different speeds.

A worked example: what the math shows today

Here's what this looks like for an actual employer, using Florida's own 2026 statewide averages rather than a single county estimate, since no Florida county in our dataset currently produces a positive spread. Assume a 15-employee Florida company weighing whether to move off small group and fund an ICHRA at the individual-market benchmark level instead.

Notice what that worked example does not argue: that ICHRA is a bad idea everywhere, or that Florida employers should ignore it. It argues something narrower and more useful, that the specific saving this site is built to identify, the individual-versus-small-group rate spread, isn't present in Florida right now. Whether ICHRA still makes sense for a Florida employer depends on a different set of reasons, covered next.

Why some Florida employers still look at ICHRA

None of the reasons below depend on individual coverage being cheaper than group. They're the reasons an employer picks ICHRA even in a county, or a state, where the rate-spread argument doesn't apply.

• No participation minimum. A traditional small-group plan typically needs 70% or more of eligible employees enrolled to stay in force. If half your Florida team is covered through a spouse's plan, that minimum can sink a group renewal regardless of price. ICHRA has no such threshold.
• It travels. A Florida-based company with remote staff in other states, or with employees split across counties with different carrier networks, gives every employee a benefit that works wherever they actually live, instead of one network that may not reach a satellite office.
• The realistic comparison is usually "nothing," not "our current group plan." Nationally, 83% of employers who started offering ICHRA or QSEHRA in 2025 had never previously offered any group coverage at all, according to the HRA Council's most recent report. For a small Florida business that has never offered benefits, the honest comparison isn't "ICHRA versus our small-group plan," it's "ICHRA versus offering nothing," which is a different conversation entirely.
• You control the number. An ICHRA contribution is a budget line you set. It doesn't move at renewal the way a small-group premium can, and it isn't exposed to the same single-year rate swing that just hit Florida's individual market.
• You stay out of plan selection. With ICHRA, the employer funds a monthly allowance and each employee chooses and buys their own plan; the employer isn't picking a single network or metal level for 40 different households with 40 different doctors, prescriptions, and preferences.

Consider a concrete case: a 12-person Fort Lauderdale marketing agency that has never offered health coverage because a small-group quote never penciled out against its margins. The rate-spread argument in this article doesn't help that agency, since Broward County shows the same reversal as the rest of the state. But a $400-a-month-per-employee ICHRA allowance still gives every one of those 12 people a real, tax-free contribution toward a marketplace plan they choose themselves, with no participation minimum to clear and no group underwriting to pass. That's not a rate arbitrage story. It's an access story, and for a business with no prior benefit, it's the one that applies.

How ICHRA adoption is actually growing

Florida's rate-spread reversal sits inside a national ICHRA adoption trend that is still compounding. The HRA Council's most recent report, Growth Trends for ICHRA & QSEHRA, Vol. 4 (aggregating anonymized 2024-2025 data voluntarily shared by 15 member organizations), found that small, non-ALE ICHRA adoption grew 52% year over year among its founding members, while adoption among applicable large employers (ALEs) grew 34% overall, with some large-employer cohorts posting 49% growth. About 92% of employers who offered an HRA in 2024 continued offering one in 2025, and the report's own sample represents nearly half a million covered employees and dependents, with the HRA Council's conservative national estimate now above one million Americans covered through ICHRA or QSEHRA arrangements.

The figure that matters most for a Florida employer weighing this for the first time is the same 83%/17% split cited above: most employers adopting these arrangements are not switching away from a group plan, they're offering coverage for the first time. That's a different decision than the one this article's rate-spread analysis addresses, and it's worth separating the two clearly before you rule ICHRA out because the county math doesn't currently favor it.

Setting up an ICHRA in Florida, if it fits

Florida does not add state-specific ICHRA rules on top of the federal framework. The same IRS, Department of Labor, and HHS final rule (2020) that governs ICHRA everywhere applies here, and the setup sequence is identical to any other state. If you've decided the reasons above outweigh the absence of a rate-spread saving, the steps that determine whether a Florida rollout goes smoothly:

1. Confirm your reason for choosing ICHRA before you model contributions. If it isn't a rate saving, be explicit internally about which of the reasons above is actually driving the decision, since that changes how you'll explain it to employees.
2. Model affordability against W-2 wages, not household income. ICHRA's affordability safe harbor tests whether an employee's required contribution toward a benchmark plan stays under an IRS-set percentage of that employee's own W-2 wages, a different mechanism entirely from the household-income cliff that hit Florida's individual market this year. An allowance that passes the affordability test preserves the employee's ability to decline it and shop the marketplace instead, though declining still means giving up the ICHRA offer for that plan year.
3. Define employee classes carefully, if you use them. ICHRA lets an employer vary contributions by permitted classes, such as full-time versus part-time or by geographic rating area, but class rules carry minimum-size requirements in some configurations, and you cannot offer the same class a choice between ICHRA and a group plan.
4. Send the required notice on time. Eligible employees need written notice at least 90 days before the plan year starts, or by their eligibility date for new hires, and the notice has specific required content about the allowance amount and the affordability determination.
5. Budget for enrollment support. Employees who have never shopped HealthCare.gov on their own, especially ones who just lost a subsidy, need guidance once, at enrollment, on how to compare plans and apply their allowance.
6. Recheck the county math at every renewal. Rates are filed annually. A reversal this size in one plan year means next year's filings deserve a fresh look, not an assumption that this year's answer holds.

See our full ICHRA setup timeline for the detailed 60-day rollout plan, including the exact notice content requirements, and our ICHRA vs. small group decision guide for the broader framework this Florida analysis fits inside.

Where small group wins, for now

How these numbers are calculated

Two separate, independent data sources point the same direction in this article, and it's worth being precise about what each one measures. Our own savings map compares, for every U.S. county, a 2026 individual-market benchmark premium, the second-lowest-cost silver plan available to a representative enrollee, the same benchmark the federal government uses to calculate premium tax credits, against a small-group benchmark premium built from comparable small-group plan filings for that rating area. Both figures come from Ideon, a licensed insurance rate-data provider, cross-verified against CMS public-use marketplace files. A county "qualifies" when the individual benchmark sits below the small-group benchmark; no Florida county does, for 2026.

The Florida Office of Insurance Regulation figures cited throughout this article measure something different but directionally consistent: a statewide, actual-enrollment-weighted average premium across all filed individual and small-group plans, not a benchmark-plan comparison. FLOIR requires every carrier to report its own average 2025-to-2026 premium change and enrollment distribution, and the department aggregates those into the statewide weighted averages in this article, published October 16, 2025. Two different methodologies, run by two different organizations, arriving at the same conclusion for Florida, is exactly the kind of independent confirmation we look for before publishing a statewide claim like this one.

Three limitations are worth stating plainly. First, both datasets describe benchmark or weighted-average premiums, not what any individual employee will actually pay after age-rating, plan selection, or subsidy eligibility. Second, FLOIR's approved-rate figures were current as of the filing dates shown and are subject to routine revision before the plan year begins. Third, rates are filed and refreshed annually; a state that shows zero qualifying counties for 2026 is not guaranteed to show the same result for 2027. We rebuild our dataset each plan year rather than reusing prior-year figures, and we recommend Florida employers do the same before every renewal.

Questions Florida employers actually ask