CHOICE: The individual market where your people live

Draft with sample values. The shading below is generated placeholder data so the design can be reviewed. It is not marketplace data. The 2026 HIX Compare files replace it before this publishes.

Data as of: draft, sample values only. Good through December 31, 2026; plan year 2027 data is expected from CMS in the coming weeks. Confirm any county on HealthCare.gov or the state exchange before relying on it.

Benchmark your group

Three steps. List your employees by ZIP code and age, describe the current plan at single coverage, and set the percentage of a reference plan you would fund. The tool estimates the current plan's metal level, prices the lowest cost gold plan for each employee at their age and location, applies your percentage, and compares the result with what you and your people pay today. The example below is made up: a 150-person employer headquartered in Columbus, Ohio, with regional offices in Indianapolis, Nashville and Charlotte, remote staff in ten metros, and a handful of people in rural counties, on a group plan costing $900 a month at employee-only rates. Everything runs in your browser, and nothing you enter is stored, sent or logged. Enter ZIP codes and ages only, never names or other identifying details.

Compliance gates

The questions to clear with counsel and an ICHRA administrator before a contribution is set. They come from the 2019 HRA rule and related guidance. This is a checklist to take into those conversations, not a legal opinion, and tick marks here are not saved anywhere.

1. Classes. Offer the ICHRA by one of the permitted classes, such as full-time, part-time, salaried, hourly, seasonal, collectively bargained, or geographic rating area. Age, health status and Medicare eligibility are not classes. Within a class, the terms must be the same, except that the amount may rise with age, up to three times the youngest participant's amount, and with the number of dependents.
2. No mixing within a class. The same class generally cannot be offered both the group plan and an ICHRA. The exception is the new-hire rule, which lets a class of new hires start on the ICHRA while current employees stay on the group plan, and that new-hire subclass is generally not subject to the minimum class sizes unless it is split further.
3. Minimum class size. Where a group plan stays in place for another class and the ICHRA class is drawn by full-time or part-time status, salaried or hourly status, or a geographic area smaller than a state, the ICHRA class must have at least 10 employees at employers under 100, 10% of employees at 100 to 200, and 20 employees above 200.
4. Notice. Participants receive a written notice at least 90 days before the plan year starts, or, for someone newly eligible, no later than the day their coverage under the arrangement begins. The notice explains the arrangement, its effect on premium tax credits, and the right to opt out, which participants must be offered at least once a year.
5. Substantiation. Every participant and covered dependent must be enrolled in individual health insurance or Medicare (Parts A and B, or Part C), and this has to be verified each year, generally before the plan year starts, and before each reimbursement.
6. Affordability and the mandate. An applicable large employer's offer is generally tested against the lowest cost silver plan for self-only coverage where the employee lives, at 9.96% of household income for 2026 and 10.22% for 2027. Final IRS regulations (T.D. 9938) add safe harbors, including one that generally lets an employer use the employee's primary worksite instead of residence for the mandate. The offer is reported on Form 1095-C.
7. The ICHRA is a group health plan. Plan documents and summaries, COBRA, HIPAA privacy, and the PCORI fee generally apply, and larger plans may have a Form 5500 filing. The individual policies themselves are generally kept outside ERISA if the employer does not select or endorse any carrier and tells employees so.
8. Pre-tax payment of the employee's share. Premium above the contribution can generally run through a cafeteria plan only for coverage bought off the exchange.
9. Medicare. An ICHRA can generally reimburse Medicare premiums for participants enrolled in Medicare, as part of a class offered on the same terms. For employers with 20 or more employees, the Medicare Secondary Payer rules at 42 CFR 411.108 list offering Medicare-entitled employees coverage that is secondary to Medicare, or steering them off the group plan, among the prohibited ways of taking Medicare into account. How that applies to a class with Medicare-enrolled employees is a question for counsel.
10. Enrollment window. Employees newly offered an ICHRA get a special enrollment period in the individual market, generally 60 days, and non-calendar plan years mean deductibles reset each January 1 regardless.

State by state

The same numbers as a table. Select a column heading to sort. Selecting a state name zooms the map to it.

How to read it

• Insurers counts every carrier with at least one individual market medical plan certified for sale on the exchange in the county, as listed in the CMS public use files, including plans also sold off it. One insurer means one network: the employee chooses a metal level, not a carrier.
• Premium change compares the same county's benchmark premium for a 40-year-old, 2025 to 2026, before any tax credit.
• PPO available shades the counties where at least one plan is filed as a PPO. Everywhere left unshaded, the choice is HMO, EPO or POS, and HMO and EPO plans generally cover no non-emergency care outside the network.
• Counties in black have no record in the source file for the measure shown.
• Deductible shows either the lowest individual in-network deductible on any standard plan sold in the county, or the typical plan's, which is the median across every plan offered there. Both exclude catastrophic plans and the reduced cost-sharing silver versions that only lower-income enrollees can buy. Where a plan keeps separate medical and drug deductibles, this is the medical one, and where a plan has two in-network tiers, it is the broader tier's. Read the two together: a low deductible is available in most counties, usually on a copay-first plan with a separate drug deductible and a high out-of-pocket maximum, while the typical plan's deductible is $2,000 or more almost everywhere. For comparison, KFF puts the average single-coverage deductible in employer group health plans at $1,886 for 2025, with 34% of covered workers at $2,000 or more.
• Benchmark premium is the second lowest cost silver plan sold on the exchange for a 40-year-old non-smoker, monthly, before any tax credit. It sets the reference point for affordability and for most contribution designs.

How the numbers were built

• Every plan, rate and service area comes from the CMS Marketplace public use files for plan years 2025 and 2026: the federal files for the states that use HealthCare.gov, and the state-based exchange files CMS publishes for the rest. Individual market medical plans only, standard plan variants only.
• Each county is priced in the rating area CMS assigns it on its state rating-area pages. Where a state draws rating areas by three-digit ZIP code rather than by county, the county takes the rating area covering most of its ZIP codes, and a county split between two rating areas, as Los Angeles is, takes the larger.
• A carrier counts in a county if its filed service area includes any part of the county. A few carriers cover only part of a county.
• Checked against published figures: in the places priced as a single rating area, including Vermont, DC, New Jersey, Rhode Island, Maryland, Arkansas, Delaware and Hawaii, the benchmark premium comes within $2 of KFF's 2026 state average. The median county benchmark here rose 25% from 2025 to 2026. KFF reported average benchmark increases of about 30% in HealthCare.gov states and 17% in state-run exchanges, weighted by enrollment, so the two are not directly comparable. This count finds 144 single-insurer counties for 2026 where KFF reports 165. KFF counts parent companies and this map counts each licensed issuer; rolling issuers up to parent company gives 164, and most of the difference is Blue Cross Blue Shield of Michigan and its HMO, Blue Care Network, filing separately.
• Rural check. Against the USDA's 2023 Rural-Urban Continuum Codes, nonmetro counties are 62% of counties but 88% of single-insurer counties. Single-insurer counties are about 1.5% of metro counties and about 9% of remote rural counties (nonmetro, not adjacent to a metro area), and the median benchmark is about 16% higher in the remote group. The share of counties with no PPO is about the same, 54% to 57%, in every group.

Assumptions and estimates, in one place

• Estimate Premiums are the 2026 rate for a non-smoker, effective January 1. States that file quarterly rate changes, including Maryland and Virginia, may charge more later in the year.
• Estimate Ages are priced on each state's own age curve, read from the CMS rate files. Premiums shown at age 40 are the base those curves scale from.
• Estimate A ZIP code is placed in the county that holds its center, from an open-source ZIP list. A county is priced in the rating area covering most of its ZIP codes.
• Estimate The current plan's metal level is a rough actuarial value from its deductible, coinsurance and out-of-pocket maximum. It is not the CMS AV Calculator and can be off by several points.
• Estimate Every example is priced against one reference plan, the lowest cost gold plan in each employee's county at their age, with the lowest cost platinum plan used where no gold plan is sold. It is a modeling convention. Employees will often choose a different plan, paying the difference if they upgrade and leaving part of the allowance unspent if they downgrade.
• Estimate The affordability figure is a screen using the 2026 percentage of 9.96% and the lowest cost silver plan, self-only. The real test uses each employee's household income and allows safe harbors not modeled here.
• Illustrative Employer and employee costs assume every employee takes employee-only coverage, buys the reference plan, and is reimbursed up to the contribution but never more than the premium.
• Illustrative The first-look label is a rule of thumb applied to these figures, not advice. It reads favorable when the comparable plans cost at least 5% less, no more than a quarter of employees pay more, and your cost does not rise more than 2%; unfavorable when comparable plans cost 10% more or at least half of employees pay more; mixed otherwise.

What this does not account for

• Which physicians and hospitals are in each network. Two insurers can share a narrow network, and one broad network can beat three thin ones.
• Where people actually live inside a county, and rating areas that split or cross county lines in a few states.
• Plan year 2027. The 2027 files are generally published in late October, and carrier exits announced for 2027 are not reflected here.
• Plans sold only off the exchange. The CMS files cover plans certified for sale on the exchange, including those also sold off it. Off-exchange-only plans are not shown, and in some counties they add options.
• Affordability for any particular employee. The benchmark section screens a roster, but the real test runs on each employee's own household income.
• Tax treatment. Whether an employee's share of premium can be paid pre-tax depends in part on whether the plan is bought on or off the exchange, and that is a question for a tax adviser.

Fringe Theory is independent and unaffiliated. Views expressed are my own and do not represent those of my employer. Nothing here is legal, tax, medical, or investment advice. Figures described as modeled or derived are my own arithmetic from the public sources listed, not disclosed data.

Sources: Centers for Medicare & Medicaid Services, Health Insurance Exchange Public Use Files (Rate, Plan Attributes and Service Area), plan years 2025 and 2026, and State-based Exchange Public Use Files, plan years 2025 and 2026; CMS, state geographic rating areas. Rural check: USDA Economic Research Service, Rural-Urban Continuum Codes, 2023. Benchmark comparisons: KFF, Marketplace Average Benchmark Premiums, 2026; KFF, ACA Insurers Are Raising Premiums by an Estimated 26%, October 28, 2025. Compliance gates: Health Reimbursement Arrangements and Other Account-Based Group Health Plans, final rule, 84 FR 28888 (June 20, 2019), 26 CFR 54.9802-4 and 29 CFR 2510.3-1(l); Revenue Procedures 2025-25 and 2026-26; 42 CFR 411.103. Group plan deductible comparison: KFF, 2025 Employer Health Benefits Survey, October 22, 2025. County boundaries: US Census Bureau cartographic boundaries via us-atlas. Nothing you select here is stored, sent or logged.

Canonical source

This artifact, until it is placed on thefringetheory.com

Captured

September 24, 2026

Status

Draft, sample values