Updated October 2026
Offering HSA, QSEHRA, ICHRA, or EBHRA in 2026: a small employer's framework
Four real options in 2026 for small employers. Each has different cost structures, compliance burdens, and employee value. Here is the neutral decision framework.
Four-option comparison (2026)
| Option | 2026 cap | Who qualifies | HSA compatible | Admin cost |
|---|---|---|---|---|
| Group HDHP + HSA contribution | $8,750 family HSA limit | Any employer | Yes | Group carrier fees |
| QSEHRA | $6,450 / $13,100 | Under 50 FTE, no group plan | No (std design) | PeopleKeep: $25/employee/mo + $50/mo base |
| ICHRA | No IRS cap | Any employer | No (std design) | PeopleKeep: from $25/employee/mo + $50/mo base |
| EBHRA | $2,200 flat | Employers that also offer a traditional group plan | Possibly | Quote from administrator |
Decision framework by employer size
Under 10 employees
Group health plans are expensive and inflexible at this size. QSEHRA is typically the most cost-effective option - no group plan required, employees choose their own coverage, employer sets the budget. Annual cost = reimbursements paid + the administrator's fee. At PeopleKeep's published rate, 5 employees is $25 x 5 + $50 = $175 a month, or $2,100 a year.
10-49 employees
QSEHRA remains attractive at this size. ICHRA becomes worth considering if you want to offer different benefit amounts to different roles (e.g., higher reimbursement for full-time salaried vs part-time hourly). Group HDHP with HSA contribution is viable if you can negotiate competitive group rates (typically through a broker).
50-200 employees (ALE territory)
At 50+ FTE you are an Applicable Large Employer under the ACA and must offer minimum essential coverage or face penalties. ICHRA is the most common HRA choice at this size as it satisfies the employer mandate if affordable. QSEHRA is no longer available (50+ FTE). Group HDHP with HSA contribution remains viable and is often competitive.
Illustrative cost model: 10-employee small business
| Option | Annual employer cost | Notes |
|---|---|---|
| Group plan, single coverage (employer pays 60%) | $55,950 | 10 x 60% x $9,325, the KFF 2025 average single premium; your carrier quote will differ |
| QSEHRA ($3,600 self-only per employee) | $36,000 + $3,600 admin | Admin at PeopleKeep's published rate: 10 x $25 + $50 = $300/mo |
| ICHRA ($400/mo per employee) | $48,000 + from $3,600 admin | No cap, employer sets dollar; PeopleKeep ICHRA starts at the same rate |
| EBHRA ($2,200 per employee) | $22,000 on top of a group plan | Cannot stand alone: a traditional group plan must also be offered |
Illustrative only. Actual costs depend on location, employee ages, chosen benefit levels, and carrier pricing. Get quotes from at least three sources before deciding.