Updated April 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) | $50-150/mo |
| ICHRA | No IRS cap | Any employer | No (std design) | $100-250/mo |
| EBHRA | $2,200 flat | Any employer; must have other coverage | Possibly | $30-80/mo |
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. Setup through PeopleKeep or Take Command takes 1-2 weeks. Annual cost = reimbursements paid + ~$1,200-1,800 in admin fees.
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 HDHP (employer pays 60%) | $60,000-$90,000 | 10 employees x ~$600-$900/mo employer share |
| QSEHRA ($3,600 self-only per employee) | $36,000 + $1,500 admin | Full employees; well below cap |
| ICHRA ($400/mo per employee) | $48,000 + $2,400 admin | No cap, employer sets dollar |
| EBHRA only | $22,000 + $600 admin | Employees must have other coverage; supplemental only |
Illustrative only. Actual costs depend on location, employee ages, chosen benefit levels, and carrier pricing. Get quotes from at least three sources before deciding.