ICHRA in Hamilton, Ohio 2026: Butler County 62.3%

Does ICHRA beat small group in Hamilton, Ohio?

Yes. An ICHRA (Individual Coverage Health Reimbursement Arrangement) is an IRS-defined arrangement that lets an employer set a fixed monthly reimbursement amount and let each employee buy their own individual-market plan with it, tax-free. In Butler County, the county whose seat is Hamilton, Ohio, the 2026 individual-market benchmark premium runs an estimated 62.3% below the small-group benchmark premium, according to a county-by-county comparison built from Ideon rate data and cross-verified against CMS public-use marketplace files.

Worth naming up front, because it trips people up: Hamilton, the city, is the county seat of Butler County, not Hamilton County, which is the county that contains Cincinnati, about 25 miles south. The two counties are different places with different names that happen to share one word. As this article explains below, they also happen to share the exact same 2026 benchmark pricing, which makes the naming coincidence a little more confusing before it becomes genuinely useful.

That 62.3% ranks 8 out of Ohio's 88 counties by percentage, sitting well above the statewide average of 54.9%. The dollar figure that matters most to a Butler County employer's budget is $10,675 per employee per year, ranking 16 of Ohio's 88 counties by that measure. Of the 1,309 counties nationwide in our dataset, 88 are in Ohio, and all 88 of them clear the $ 100-a-month gap we use as the floor for calling a county "qualifying" at all — Ohio is one of a small number of states where every county clears that bar, a point our statewide Ohio guide covers in more depth.

Why Butler County's number matches Cincinnati's exactly

Our earlier guide to Ohio's rating areas explains a pattern that holds across much of the state: carriers file one benchmark price for a whole cluster of counties at once, a federally defined geography called a rating area, so several counties end up showing the identical number to the cent. Butler County is a clean example of that pattern in action. Checked against every other Ohio county in our dataset, Butler's individual benchmark ($537.84) and small-group benchmark ($1427.41) match 2 other counties exactly, including Hamilton County and Warren County, which contains Cincinnati.

That's a useful, practical fact for a Hamilton or Fairfield employer with staff who live in Cincinnati, West Chester, or Mason: the county-level benchmark math doesn't change at the Butler County line. A business with a mixed Butler-Hamilton-Warren workforce can use one comparison for the whole team rather than pulling a different number for each employee's home address. That's not true everywhere in Ohio — our Morrow County guide covers a county whose number matches none of its neighbors — so it's worth confirming for your specific counties rather than assuming it, which this article does for Butler, Hamilton and Warren.

Source: src/data/qualified_counties.json, 2026 plan year (Ideon rate data, cross-verified against CMS public-use marketplace files). Estimates, not quotes.

Hamilton's manufacturing economy, in the numbers

Butler County is part of the Cincinnati metropolitan area, but Hamilton, its county seat, has run its own manufacturing economy since well before Cincinnati's suburbs reached this far north. Per the Butler County Finance Alliance (BCFA), the county's economic-development organization, Butler County "has provided manufacturers with talent, infrastructure, and cost advantages for over 175 years," pointing specifically to "Hamilton's historic machine tool and steel production" as the foundation, since evolved to include "precision aerospace and automotive suppliers." One named example from BCFA's own materials: Magellan Aerospace Middletown, which manufactures "high-temperature alloy components, honeycomb structures, and assemblies," and is NADCAP-approved, an aerospace-industry quality certification.

BCFA puts the county's manufacturing workforce at 19,931 workers, or 14.5% of the county's laborshed, with access to "2,700+ annual engineering degree completions within 50 miles" — a talent-pipeline figure the alliance uses to pitch the county to manufacturers considering a Butler County location. That civic-marketing framing is worth naming plainly; it's still a useful, specific, named-source figure for understanding why a Hamilton manufacturer competes for labor the way it does.

Per the U.S. Bureau of Labor Statistics' Quarterly Census of Employment and Wages (QCEW) for Butler County (area code 39017), 2025 annual averages, the county's 9,010 private-sector establishments employed 146,248 people at an average annual pay of $67,037. Manufacturing, 470 establishments strong, employed 25,364 people at an average annual pay of $93,391 — the best-paying major private sector in the county by a wide margin, and well above the countywide private average. Construction employed 9,264 people across 709 firms at $91,076 average pay, nearly matching manufacturing's wage level. Retail trade employed 16,397 people across 1,092 firms at $40,122 average pay, while accommodation and food services, the lowest-paid major sector, employed 17,001 people across 855 firms at just $23,177 average pay. Local government employed 13,213 people across 238 establishments at $65,765 average pay.

Source: U.S. Bureau of Labor Statistics, Quarterly Census of Employment and Wages, Butler County, Ohio (area code 39017), 2025 annual averages.

Why a Butler County manufacturer feels group-insurance pricing the hardest

A 22-person precision machine shop in Hamilton, a specialty fabricator in Fairfield, or a family-run distribution business along the I-75 corridor all share a version of the same problem. None of them is large enough to negotiate group-insurance pricing the way a major employer can, and none has the kind of stable, uniformly full-time payroll that small-group underwriting assumes. A fabrication shop might run lean on office staff while carrying a skilled-trades crew that's exactly the kind of higher-wage, harder-to-replace worker an owner most wants to compete for with a real benefit, especially with Butler County's manufacturing wage average sitting at $93,391, a number that tells you these aren't minimum-wage positions easily filled from a larger applicant pool.

Group health insurance is priced and underwritten around a knowable, largely stable enrolled population. A carrier protects that pricing with a minimum enrollment share among eligible employees before it will issue a policy, and the exact bar is set by the carrier, not capped by Ohio statute (more on that below). For a small Butler County employer with a mix of full-time shop staff, part-time administrative help, and employees already covered through a spouse's plan, clearing whatever bar a given carrier happens to set is a real obstacle — one that has nothing to do with whether the employer wants to offer a benefit and everything to do with a workforce shape group underwriting wasn't built for.

This is the pain point this guide is written for: an owner who priced group coverage, ran into either the participation math or a renewal number that jumped without warning, and assumed there was nothing realistic to offer, when in fact Butler County's individual market is priced low enough, relative to small group, that a modest fixed monthly contribution goes further here than in most other Ohio counties.

See the full Ohio savings breakdown for every qualifying county, the national savings map to look up a specific county by name, or the Ohio vs. Georgia comparison for how Butler's number fits into the bigger multi-state picture.

How an ICHRA (now also called CHOICE) actually works

Before the Butler County numbers mean anything, it helps to be precise about what's being compared.

An ICHRA is an employer-funded health reimbursement arrangement created by a 2019 final rule from the IRS and Treasury, the Department of Labor, and HHS, published in the Federal Register on June 20, 2019, applicable to plan years beginning on or after January 1, 2020. Instead of choosing one group health plan for everyone, the employer sets a fixed monthly reimbursement amount, and each employee uses that money to buy an individual-market plan of their own choosing, then submits proof of coverage (called substantiation) to get reimbursed tax-free. The employer isn't picking a plan for a shop floor of households with different doctors and different needs; the employer is funding a budget, and the employee is doing the shopping.

Worth naming directly: as of this article's publish date, HealthCare.gov's own page on this arrangement is titled "CHOICE Arrangements," and states plainly that CHOICE Arrangements are "formerly known as the Individual Coverage Health Reimbursement Arrangements, or ICHRAs." That's an administrative renaming on federal consumer-facing pages, not a change to the 2019 final rule or to any compliance requirement described in this article. We use "ICHRA" throughout this site, since that's still the term used in the regulations themselves.

The comparison behind every number in this article rests on two specific prices for a given rating geography. The individual-market benchmark premium is the second-lowest- cost silver-level plan available to a representative 40-year-old enrollee. "Silver" is one of four ACA metal levels (bronze, silver, gold, platinum) describing how costs split between premium and out-of-pocket spending, not the quality of care. This is the same benchmark the federal government uses to calculate premium tax credits, which is why it's a defensible number to build a comparison on rather than one insurer's list price. The small-group benchmark premium is the equivalent figure built from comparable small-group plan filings for the same geography. When the individual benchmark is lower, the county "qualifies," and the gap between the two is the estimated per-employee savings if the employer funds ICHRA at that benchmark level.

Two more terms matter once an employer is actually deciding whether to switch. The affordability safe harbor is the test that decides whether the ICHRA offer counts as "affordable" under IRS rules — for plan years beginning in 2026 that test runs against a Required Contribution Percentage of 9.96% of household income (IRS Rev. Proc. 2025-25), rising to 10.22% for plan years beginning in 2027 (IRS Rev. Proc. 2026-26). Get the contribution amount wrong relative to that threshold and an ALE (applicable large employer, generally 50 or more full-time-equivalent employees) can trigger an employer-mandate penalty. Most Butler County machine shops, fabricators and small distributors, running well under 50 employees, sit comfortably under that threshold, though a growing shop near Hamilton's industrial corridor should model it before crossing 50 heads.

Butler County's rate spread, in dollars

Here is the actual 2026 benchmark comparison for Butler County, the county whose seat is Hamilton, Ohio. The individual-market benchmark premium is $537.84 a month. The small-group benchmark premium, built from comparable small-group plan filings for the same geography, is $1427.41 a month. That's a gap of $889.57 a month, or $10,675 a year, per employee, an estimated 62.3% in favor of the individual market.

Put next to the rest of the Cincinnati-Dayton corridor, Butler's percentage ties Hamilton County (Cincinnati) and Warren County exactly, at 62.3%, and runs ahead of Preble County's 58.3% and Montgomery County's (Dayton) 58.3%. Because the three matching counties share the exact same benchmark prices, the per-employee dollar savings figure, $10,675 a year, is also identical across Butler, Hamilton and Warren counties — a rare case on this site where neighboring geographies genuinely do share one answer, not just a similar one.

Ohio's group participation rule, and why there's no state-set ceiling

Small-group health insurance isn't sold to individual employees one at a time; it's underwritten as a pool, and a carrier can require a minimum share of a company's eligible employees to actually enroll before it will issue the policy at all. Ohio law defines this mechanic in Ohio Revised Code § 3924.03(E)(1), which states that "'group participation rule' means a requirement relating to the minimum number of employees or dependents that must be enrolled in relation to a specified percentage or number of eligible individuals or employees of an employer." The same subsection permits a small-group carrier to establish such a rule "as allowed under the law of this state," but the statute itself does not cap the percentage a carrier is allowed to require.

In practice, that means a Butler County employer shopping small-group coverage may see a different minimum-participation requirement from one carrier to the next, and that requirement isn't published anywhere in one place the way a statutory cap would be; it has to be confirmed plan by plan. A 20-person machine shop with a couple of part-timers, a new hire still inside a waiting period, or an employee covered elsewhere can end up short of whatever bar a given carrier happens to set, even though every one of those employees technically has coverage somewhere.

An ICHRA (or CHOICE Arrangement, per HealthCare.gov's current naming) sidesteps the mechanic entirely when it's the only benefit offered. Per HealthCare.gov, there is no participation-percentage requirement at all in that case. A minimum class size only applies when an employer offers a CHOICE Arrangement to one employee class while also offering a traditional group plan to a different class: 10 employees for employers with fewer than 100 total employees, 10% of the total workforce for employers with 100 to 200 employees, and 20 employees for employers with more than 200. Those class-size rules exist to keep the two benefit types properly separated when both are in use; they don't apply at all to an employer offering only a CHOICE Arrangement, which describes most Butler County small businesses.

A worked example for a Butler County employer

Here's what the Butler County numbers look like applied to a real headcount. Assume a 14-employee Butler County company — a precision machine shop in Hamilton, a fabricator in Fairfield, or a small distribution operation along the I-75 corridor — currently renewing a small-group plan priced at this year's Butler County benchmark.

The same arithmetic scales down cleanly to a smaller case: a 5-person specialty fabrication shop in Hamilton that never seriously priced group coverage because the owner assumed a business that small couldn't offer anything worth having. At the $ 537.84 individual benchmark, funding an ICHRA for all five employees costs about $2689 a month in total contributions — a real, tax-free benefit offered to every eligible employee, since there's no enrollment percentage to clear and no group underwriting to qualify for.

At the other end of the size range, a 55-employee precision manufacturer along the I-75 corridor crosses into ALE territory under the employer mandate, which changes the calculus without changing the underlying county math. The same benchmark comparison applies, but an ALE has to run the affordability safe-harbor test — against the 9.96% threshold for 2026 or 10.22% for 2027 — carefully for every employee class, since an ICHRA offer judged "unaffordable" for even a handful of lower-paid employees can trigger a penalty. That's not a reason to avoid ICHRA at that size; it's a reason to model the affordability test before setting a contribution amount, which our eligibility guide walks through in detail.

Setting up an ICHRA in Butler County

Ohio doesn't layer a statewide participation cap on top of the federal framework the way some states do, but the underlying setup sequence is the same one that applies everywhere. What determines whether a Butler County rollout goes smoothly:

1. Pull your census by county, not by office address. A business headquartered in Hamilton with staff commuting in from Cincinnati (Hamilton County) or Mason (Warren County) will see the same benchmark numbers, since all three share the same rate area — but staff commuting from Preble or Montgomery counties see a different, lower percentage, so check each employee's home county rather than assuming the Butler number applies to everyone.
2. Decide how you'll define your eligible class. An hours-based eligible class (for example, employees regularly scheduled 30+ hours a week) is a legitimate way to extend a benefit to full-time shop or administrative staff without promising it to every part-time or seasonal hire.
3. Check whether you're offering ICHRA alone or alongside a group plan. That decision determines whether any class-size minimum applies at all.
4. Model affordability before you set a contribution. The reimbursement level decides whether an employee keeps or waives premium tax credit eligibility, against the 9.96% (2026) or 10.22% (2027) Required Contribution Percentage.
5. Send the required notice on time. Eligible employees need written notice at least 90 days before the plan year starts, with specific required content.
6. Budget for onboarding support. Shop-floor and administrative staff who've never shopped Ohio's individual marketplace need guidance once, at enrollment, not a lengthy annual open-enrollment process.

See our full ICHRA setup timeline for the detailed rollout plan, including the exact notice content requirements, and our eligibility guide for the affordability test itself.

The honest limits of this data

How these numbers are calculated

Every county figure in this article comes from the same dataset that powers our savings map, not a survey or a sales estimate. For each county, we compare 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 geography. Both figures come from Ideon, a licensed insurance rate-data provider, and are cross-verified against CMS public-use marketplace files before publication. A county appears in our location-page dataset when the individual benchmark sits below the small-group benchmark by at least $100 a month; the percentage and dollar figures in this article are the gap between those two numbers, expressed as an annual per-employee figure at 12 times the monthly difference.

Butler County's population figure (388K) comes from the same underlying county dataset used across the site. The employment figures in the economy section — 146,248 total private jobs across 9,010 establishments at $67,037 average pay, 25,364 manufacturing jobs across 470 establishments at $93,391 average pay, 9,264 construction jobs across 709 establishments at $91,076 average pay, 16,397 retail-trade jobs across 1,092 establishments at $40,122 average pay, 17,001 accommodation-and-food-services jobs across 855 establishments at $23,177 average pay, and 13,213 local-government jobs across 238 establishments at $65,765 average pay — come from the U.S. Bureau of Labor Statistics' Quarterly Census of Employment and Wages, Butler County, Ohio (area code 39017), 2025 annual averages, a separate federal dataset from our own county premium comparison, fetched directly from BLS's public CEW API. The total covered (all ownerships) figure of 163,638 jobs across 9,290 establishments comes from the same BLS source. The county's manufacturing history, its named example employer (Magellan Aerospace Middletown), and the 19,931-worker, 14.5%-of-laborshed manufacturing-employment figure come from the Butler County Finance Alliance's own published target-industries materials. The Ohio participation-rule citation comes directly from the text of Ohio Revised Code § 3924.03(E)(1), as published by the Ohio Legislative Service Commission at codes.ohio.gov. The national small-group premium figure (Peterson-KFF), the Ohio individual-market figures (healthinsurance.org), the IRS affordability percentages (Rev. Proc. 2025-25 and 2026-26), and the HealthCare.gov participation and naming details each come from separately published, independent sources, described and cited where they appear. We've kept these data sources clearly separate throughout this article rather than blending them into one number.

Three limitations are worth stating plainly. First, benchmark premiums are built around a representative enrollee profile, so an unusually young or unusually old workforce will see a different real-world spread than the county figure implies. Second, these are benchmark plans, not every plan on the market; an employee who chooses a richer or leaner plan than the benchmark will see a different premium, though the relative spread tends to hold directionally. Third, rates are filed and refreshed annually, so a geography that qualifies for 2026, and even a three-county match like Butler, Hamilton and Warren, is not guaranteed to hold its current percentage, or stay matched, for 2027 if a carrier enters or exits that rate area.

Questions Butler County employers actually ask