ICHRA in Kansas 2026: Topeka Wins, Wichita Falls Short

Does ICHRA beat small group in Kansas?

In most of the state, yes, and in a specific, identifiable band of counties it beats small group by a wide margin. An ICHRA (Individual Coverage Health Reimbursement Arrangement) clears our $100-a-month-per-employee qualifying bar in an estimated 73 of Kansas's 105 counties for the 2026 plan year, based on a county-by-county comparison of individual-market and small-group benchmark premiums. Those 73 counties make up about 6% of the 1309 counties nationwide where the math currently favors ICHRA, and cover an estimated 65% of Kansas's population.

If you haven't worked through the general decision yet, our ICHRA vs. small group decision guide walks through the framework this article applies specifically to Kansas. Here's the part a simple "Kansas qualifies" headline hides: the state's biggest county doesn't clear the bar at all. Sedgwick County, home to Wichita and Kansas's largest single population center at over half a million residents, shows only a 7.0% discount, too thin to be the point of the exercise. Meanwhile Shawnee County, home to the state capital, and Douglas County, home to Lawrence and the University of Kansas, both clear 33.2%, the widest margin in the state. That range, not a single statewide percentage, is the actual finding here.

Why Kansas's rates keep climbing

Kansas employers are looking at one of the steepest individual-market increases in the country, on top of a small-group market that's climbing in its own right. Kansas's individual-market carriers posted a final weighted average rate increase of 26.6% for the 2026 plan year, according to rate data compiled by ACA Signups from the federal Rate Review database and SERFF filings. That final figure came down from a preliminary 30.5% once the database was updated with approved rates, but it's still one of the largest individual-market increases filed anywhere for 2026. The Kansas Health Institute, an independent nonprofit health policy research organization, reported the same trend from a different angle: the benchmark silver plan for a family of four rose an estimated 28.9%, from $1,848 to $2,381 a month before subsidies, the largest jump since 2019. Two different organizations, two different measurements, the same scale of increase.

Preliminary 2027 filings run a weighted 19.5% increase for the individual market (ranging from 15.4% to 34.81% by carrier) and an unweighted 11.5% increase for the small-group market, again per ACA Signups' compilation of the federal Rate Review database. UnitedHealthcare filed the single largest request of any carrier in the state, between 29.68% and 36.48%, according to the Beacon News's review of the filing. Insurers point to rising health-care costs, the expiration of enhanced ACA subsidies pulling healthier people out of the individual-market risk pool, and Kansas's status as a non-expansion state, which concentrates higher-risk adults in that same individual market, as the drivers behind the increases.

None of this happens in a vacuum. When small-group rates move up, as filed for Kansas's 2027 plan year, the spread this entire strategy depends on can widen, because ICHRA reimbursements ride on individual-market prices, not small-group prices, even if individual-market rates keep rising too, so long as they don't rise as fast. That's exactly why every figure in this article is tied to a specific plan year, and why we rebuild the underlying county dataset every year rather than reusing prior numbers.

All 105 counties, three tiers

Kansas has 105 counties, one of the higher county counts of any US state, and this dataset sorts them into three distinct groups for 2026: 73 that clear the $100-a-month qualifying bar, 12 that show a smaller, real discount but fall short of it, and 20 that show no individual-market cost edge over small group at all. Savings across the 73 qualifying counties run from 12.9% up to 33.2%, averaging 19.2%.

Johnson County, the state's most populous at over 610,000 residents and the anchor of the Kansas City metro's affluent southern suburbs, qualifies at 22.3%, alongside neighboring Wyandotte County (Kansas City, Kansas itself) at the identical 22.3%. That matters because it rules out the easy assumption that ICHRA only works in Kansas's rural counties: the state's largest metro qualifies solidly. Riley County, home to Manhattan and Kansas State University, and Saline County, home to Salina, both clear 20.3%. Sedgwick County, Wichita's home and the state's single largest county by population, is the outlier among the ten largest: it's the only one of the ten that doesn't clear the qualifying bar at all.

See the full Kansas savings breakdown for every qualifying county, or the national savings map to check a specific county by name.

Why Kansas's biggest county is its weakest

Sedgwick County's 2026 individual-market benchmark runs $750 a month against a small-group benchmark of $806, a gap of just $56, or 7.0%, worth about $675 a year per employee. That's a real, positive number, not nothing, but it's the thinnest kind of case this dataset can make, and it falls short of the $100-a-month bar we use to build a dedicated county page. Wichita anchors a diversified metro economy (aircraft manufacturing, health care, agriculture-adjacent business), and its individual market is competitively priced enough that small-group coverage there isn't carrying the premium it carries in Shawnee or Douglas County.

Eleven other Kansas counties land at the exact same 7.0% figure: Butler, Chase, Chautauqua, Cowley, Elk, Greenwood, Harper, Marion, Montgomery, Sumner, Wilson. Identical premiums across a cluster of counties like that usually mean one thing: they share the same individual-market rating area, a geographic pricing zone that Kansas and most other states define for ACA marketplace plans. When a whole rating area prices the same, one county's story is every county's story in that area. Our sister article on how rating areas create identical premiums across different counties walks through the general mechanism in more depth, using Ohio as the example.

A worked example: Topeka versus Wichita

Here's what the county-level math actually looks like for a small employer with a split Kansas workforce, using real 2026 rate data for the two counties named in this article's headline. Assume a 20-employee company with 12 employees in Shawnee County (Topeka) and 8 employees in Sedgwick County (Wichita).

Notice what this example does not do: claim a single statewide "Kansas saves X%" figure. A headline like that would blur the fact that the Topeka side of this workforce is worth roughly six times more per employee than the Wichita side. Checking counties individually, not trusting a state average, is the entire argument for county-level data, and Kansas is one of the clearer examples of why that matters, because its largest county by population is also its weakest ICHRA county.

The affordability test, in plain numbers

Every ICHRA has to clear the IRS's affordability test to avoid pushing an eligible employee's premium tax credit decision the wrong way. Under IRS Revenue Procedure 2025-25, the required contribution percentage for plan years beginning in 2026 is 9.96% of household income. In plain terms: an employer's ICHRA is considered affordable for an employee if that employee's own required monthly contribution toward the lowest-cost silver plan in their rating area doesn't exceed 9.96% of their household income, divided by 12.

The subsidy trade-off, stated plainly

Taking an ICHRA is not free money layered on top of a marketplace subsidy. Per HealthCare.gov's own guidance on individual coverage HRAs: if an employer's offer is considered affordable, the employee and their household members "won't be eligible for the premium tax credit on Marketplace coverage, even if they don't use the Health Reimbursement Arrangement." If the offer isn't considered affordable, the employee can choose between the ICHRA and the premium tax credit, "but not both": to get the premium tax credit, they have to decline the ICHRA offer entirely.

Why more Kansas employers are looking at this now

Kansas's rate filings aren't happening in a vacuum. The HRA Council, an industry association that aggregates anonymized enrollment data from 17 member organizations, released its newest annual report on August 12, 2026: Growth Trends for ICHRA & QSEHRA, Vol. 5. It found that more than 20,000 US businesses now offer ICHRA or QSEHRA, covering at least 500,000 employees nationally as of January 31, 2026. Among small employers, more than two-thirds of those offering ICHRA, and 93% of those newly offering QSEHRA in 2026, had previously offered no health coverage at all. Applicable Large Employers were the fastest-growing segment, more than doubling their average ICHRA adoption since the prior year, and more than half of enrollments nationally, on- and off-exchange, are by employees under 45.

That distinction matters for a Kansas employer weighing this for the first time. On the current individual marketplace, Kansas's 2026 open enrollment period saw 192,811 plan selections, down from 200,046 during the 2025 open enrollment period, a 3.6% year-over-year decline, according to KFF's Marketplace Enrollment Snapshot for the 2026 open enrollment period. Kansas uses HealthCare.gov as its marketplace platform in both years, so that drop reflects real people leaving the individual market, not a technical platform change. For most small businesses in the state's qualifying counties, the realistic comparison isn't "ICHRA versus our current group plan." It's "ICHRA versus offering nothing," which is a much easier case to make when you're competing for talent against employers who already offer some kind of benefit, and a more urgent one with individual-market rates already up 26.6% for 2026 and small-group filings up 11.5% for 2027. The IRS, DOL and HHS final rule that created ICHRA in 2020 sets no employer size minimum at all; a single-employee company can offer one on the same terms as a 500-person company, part of why adoption keeps climbing fastest among the smallest employers in the HRA Council's data.

How ICHRA Savings helps

None of the county math above requires talking to anyone. The savings map lets you look up every Kansas county by name and see the same individual-market and small-group benchmark premiums used in this article, so you can check whether your specific workforce sits inside a strong-margin county like Shawnee or Douglas, a thin-margin one like Barber, or one of the twelve that don't clear the bar at all, before you spend time on anything else. Beyond the map, we help employers design and set up an ICHRA: building employee classes correctly, modeling affordability against your real census instead of a rule of thumb, and getting the required employee notice right and on time. We don't pick your employees' plans for them; that decision, and the choice of network, stays with each person buying their own coverage. Our part is the budget, the design and the compliance scaffolding around it.

Before anything else, check whether your county is one where this works well: https://ichrasavings.com/ichra-savings-map/. Ten minutes there tells you whether the rest of this process is worth starting, and whether your county lands closer to Shawnee's 33.2% or Sedgwick's 7.0%.

One more wrinkle worth flagging for Kansas specifically: the Kansas City metro straddles the Kansas-Missouri state line, and Johnson and Wyandotte Counties on the Kansas side price differently than Jackson and Clay Counties on the Missouri side. An employer with staff living on either side of that line needs each employee's actual county checked individually: Missouri runs its own separate rate filings and its own separate qualifying counties on our savings map, not a mirror of Kansas's numbers.

Setting up an ICHRA in Kansas

Kansas doesn't add state-specific ICHRA rules on top of the federal framework. The same IRS, DOL and HHS final rule that governs ICHRA everywhere applies here, and the setup sequence is identical to any other state:

1. Pull your census by county, not by office address. A company headquartered in Wichita with field or remote staff in Topeka, Lawrence or Manhattan has a materially different savings story per location.
2. Check each employee's county on the savings map. Don't assume a statewide average applies; a 33.2% county and a 7.0% county both technically sit in "Kansas," but they aren't the same decision.
3. Model affordability using the 2026 threshold. At 9.96% of household income, the required contribution percentage sets how much an ICHRA contribution needs to cover to count as affordable.
4. Define employee classes carefully, if you use them. An employee class is a group defined by an objective factor the IRS permits, such as full-time versus part-time status, geographic location, or salaried versus hourly work. Class rules carry minimum-size requirements and cannot offer the same class a choice between ICHRA and group coverage.
5. Send the required notice on time. Under 26 CFR § 54.9802-4(c)(6), eligible employees generally need written notice at least 90 calendar days before the plan year begins, with specific required content about the offer and its effect on subsidy eligibility.
6. Budget for onboarding support. Employees who have never shopped Kansas's individual marketplace on their own need guidance, once, at enrollment, especially with coverage options varying meaningfully by county and rating area.

See our full ICHRA setup timeline for the detailed rollout plan, including the exact notice content requirements, and our guide to ICHRA employee classes if your Kansas workforce spans more than one rating area.

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 from a survey or a sales estimate. For each of Kansas's 105 counties, we compare a 2026 individual-market benchmark premium, the second-lowest-cost silver plan available to a representative enrollee, against a small-group benchmark premium built from comparable small-group plan filings for that county's rating area. A county "qualifies" for its own page when the gap between those two benchmarks reaches at least $100 a month per employee; 73 of Kansas's 105 counties clear that bar for 2026. Another 12 show a smaller, positive gap that falls short of it. The remaining 20 aren't in the underlying dataset at all, meaning the individual-market benchmark in those counties doesn't run below the small-group benchmark for 2026. Kansas's total county count comes from the U.S. Census Bureau's 2020 county reference file; the state's 2024 population estimate, used to calculate the population share of qualifying counties, comes from the Census Bureau's Population Estimates Program. The 2026-final and 2027-preliminary statewide rate-filing figures come from the federal Rate Review database and SERFF filings as compiled by ACA Signups, corroborated by the Kansas Health Institute's independent benchmark-premium estimate; neither is reflected in the county-level qualifying dataset above, which uses the 2026 benchmark comparison described here.

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 average 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 county that qualifies for 2026 is not guaranteed to qualify for 2027 once the current filings are approved. We rebuild this dataset each plan year rather than reusing prior-year figures, and we recommend employers do the same before every renewal.

Questions Kansas employers actually ask