ICHRA in New Hampshire 2026: Manchester Wins, Keene Lags

If a Manchester or Concord broker just handed you a small-group renewal number that jumped double digits again, and this article found you while you were searching for an alternative before you sign it, you're the reader this is written for. New Hampshire's small-group carriers have already filed for another increase on top of whatever you're renewing at now, and the state's workforce skews toward higher pay than most of New England, which means more of your employees are sitting right at the income line where a federal subsidy stops helping them at all. An ICHRA doesn't fix either of those facts. It gives you a fixed number you choose instead of one a carrier sets, and it gives your employees a tax-free way to buy coverage that fits their own household, not a one-size plan picked for the whole company.

Does ICHRA beat small group in New Hampshire?

Yes, everywhere in the state, though not by the same amount everywhere. An ICHRA (Individual Coverage Health Reimbursement Arrangement) currently beats traditional small-group coverage in all 10 of New Hampshire's 10 counties for the 2026 plan year, based on a county-by-county comparison of individual-market and small-group benchmark premiums. That's a cleaner result than most states get: New Hampshire is small enough, and priced consistently enough, that there's no county anywhere in the state where the math currently favors small group.

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 New Hampshire. Here's what a simple "all 10 counties qualify" headline hides: the win splits cleanly into two tiers, and they're not close. Belknap, Hillsborough, Merrimack, Rockingham and Strafford Counties, the five most populous in the state and home to Manchester, Nashua, Concord, Portsmouth and the Seacoast, clear a 24.4% spread. Carroll, Cheshire, Coos, Grafton and Sullivan Counties, covering the Lakes Region, the Upper Valley, the Monadnock Region and the North Country, clear a thinner 9.6%. Every county "qualifies." The size of the win depends entirely on which five you're in.

Why every county shares one small-group number

Here's the mechanism, and it starts with a term worth defining: a geographic rating area is a federally recognized region within a state that insurers use as the basis for pricing ACA-regulated health plans. Most states carve themselves into several rating areas, often along metro-versus-rural lines, so a small-group premium in a big city can be priced differently than one two counties over. New Hampshire doesn't do this. According to the Centers for Medicare & Medicaid Services (CMS), New Hampshire runs a single statewide rating area, "Rating Area 1," covering all 10 counties for both the individual and small-group markets. That's why the small-group benchmark premium used in this article is identical, to the cent, in Coos County on the Canadian border and Hillsborough County in the state's largest metro: $641 a month either way.

This is unusual, and it's worth being specific about why it matters here. In a state with several rating areas, like Missouri or Ohio, part of the variation in ICHRA savings from county to county comes from the small-group side moving around. In New Hampshire, that variable is locked. Whatever separates Hillsborough County's 24.4% from Cheshire County's 9.6% has nothing to do with small-group pricing differences, because there aren't any. It all comes from the other side of the comparison.

The two-tier split, and why the rating area doesn't explain it

A rating area sets the pricing rules insurers must follow. It doesn't require every insurer to sell every plan in every county. The individual-market figure used throughout this article is a benchmark premium, the second-lowest-cost silver-tier plan actually priced for a representative 50-year-old enrollee in that specific county, which depends on which carriers choose to compete there, not on the formal rating-area boundary. In the five-county tier anchored by Manchester and Nashua, that benchmark runs $484 a month. In the five-county tier anchored by Keene, Berlin, Littleton and the Upper Valley, it runs $579, nearly $100 a month higher, even though both tiers are priced under the exact same statewide rating rules.

The honest reading is that New Hampshire's more rural counties see a less competitive individual market, which pushes their benchmark premium up and narrows the gap against small group. It's the opposite of the pattern you'd see in a state like Colorado or Washington, where the biggest, most expensive metro often has the thinnest ICHRA margin. In New Hampshire, the state's largest, wealthiest metro area, the Manchester-Nashua-Concord-Portsmouth corridor, has the widest margin, and the more rural west and north has the thinnest. That's worth saying plainly, because county-level data doesn't always favor big cities less, and New Hampshire is the clearest example of that reversal on this site so far.

Why New Hampshire's 2027 rate filings matter now

New Hampshire employers renewing small-group coverage this year are looking at another increase before the current one even settles. The state's individual-market carriers filed preliminary 2027 rates averaging a weighted 17.7% increase, and small-group carriers filed averaging 12.4%, according to rate data compiled by ACA Signups from New Hampshire Insurance Department (NHID) and SERFF filings, published August 25, 2026. That figure is corroborated independently: HealthInsurance.org, citing the federal RateReview.HealthCare.gov database as accessed on August 4, 2026, reports the same carrier-by-carrier ranges with a weighted average closer to 18.4%, a difference that comes down to how each source weights plan-level detail, not a disagreement about the underlying filings.

Neither number is final. New Hampshire's preliminary rates were available for review by August 1, 2026, and the NHID expects final, approved 2027 rates posted by November 1, 2026. Insurers cited rising hospital and physician prices, new specialty medications and higher member utilization as the primary drivers in their filings, the same cost pressures showing up in rate filings nationwide this cycle.

This matters for an ICHRA specifically because ICHRA reimbursements track individual-market prices, not small-group prices. A filed small-group increase of 12.4%, smaller than the individual-market filing this time, could narrow New Hampshire's ICHRA spread somewhat for 2027 if both land close to their preliminary numbers, which is exactly why every figure in this article is tied to the 2026 plan year and should be rechecked once 2027 rates are final.

The carrier filings, one by one

The 17.7% statewide figure for 2027 blends a field that's about to get smaller. Celtic Insurance Co., which sells as Ambetter, is exiting New Hampshire's individual market entirely at the end of 2026, a move that will send an estimated 11,600 enrollees shopping for a new plan during open enrollment for 2027. Among the four carriers staying, Matthew Thornton Health Plan, an Anthem Blue Cross Blue Shield division, carries New Hampshire's largest individual-market block at roughly 38,800 members and filed plan-level increases ranging from 12.4% to 24.7%. Anthem Health Plans of NH, which sells an HMO product exclusively off-exchange to about 13,400 members, filed a wider range of 8.4% to 25.3%. Boston Medical Center Health Plan, which sells as WellSense to roughly 7,608 members, filed the steepest range of any continuing carrier: 17.0% to 41.2%. Harvard Pilgrim Health Care of New England, the smallest player at about 1,249 members, filed the mildest average increase, 10.7%, with a plan-level range of 6.4% to 19.9%.

Losing one of five individual-market carriers, especially one with a meaningful enrollment base, is the kind of detail that's easy to miss in a single statewide percentage but matters directly to an ICHRA rollout: it means fewer, not more, plan options for employees shopping with their ICHRA contribution in New Hampshire's 2027 open enrollment, even though four carriers remain competitive across most of the state's 10 counties.

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

A worked example: Manchester versus Keene

Here's what the county-level math looks like for a small employer with a split New Hampshire workforce, using real 2026 rate data for two qualifying counties. Assume a 20-employee company with 12 employees in Hillsborough County (Manchester and Nashua) and 8 employees in Cheshire County (Keene).

Scale the same math to a bigger, more realistic New Hampshire employer centered entirely on the Manchester-Nashua area. A 50-person firm could see an estimated $93,978 a year in aggregate savings if it funded ICHRA contributions at the benchmark level across the board (50 x $1,880). That isn't a guarantee. It assumes every employee enrolls in a plan priced near the benchmark, and real households will land above or below it depending on age, plan choice and household size. It's a real number built from real 2026 rate data, not a sales estimate, and it's the number a Manchester-area employer should actually model before writing off ICHRA as "not enough" based on a statewide average.

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, the highest this figure has ever been. 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 county doesn't exceed 9.96% of their household income, divided by 12.

There's a second, more conservative route: the federal poverty line (FPL) safe harbor, which uses a fixed income figure rather than each employee's actual wages, so it guarantees affordability for every employee regardless of income if the employer clears it. For a calendar-year 2026 plan, federal rules require using the FPL guideline in effect within six months before the plan year starts, which is the 2025 guideline: $15,650 for a single person in the 48 contiguous states. At 9.96%, that works out to an affordability ceiling of $130 a month. To clear the FPL safe harbor for every Hillsborough County employee regardless of income, an employer would need to contribute at least $354 a month ($484 minus $130), a higher bar than the W-2 example above, but one that removes the need to check each employee's income individually.

Why this matters more with the subsidy cliff back

New Hampshire has one of the highest median household incomes in the country, which means more of its workforce sits near or above the income line where ACA premium tax credits disappear entirely. Enhanced federal premium tax credits expired at the end of 2025, and the 400% federal poverty line cliff is back for the 2026 plan year: under the 2026 HHS poverty guidelines, published in the Federal Register on January 15, 2026 and effective January 13, 2026, the guideline for the 48 contiguous states and DC is $15,960 for one person and $33,000 for a family of four, putting 400% of the poverty line at $63,840 for a single person and $132,000 for a family of four. A household over that line gets no premium tax credit at all, on or off an employer's ICHRA.

That's part of why an employer-funded ICHRA contribution has become a more meaningful offer in a state like New Hampshire than it was when more generous subsidies reached further up the income scale. New Hampshire's ACA marketplace enrollment reflects some of that shift already: the state saw 66,024 marketplace plan selections during the 2026 open enrollment period, down from 70,337 in 2025, an 8% decline, according to the KFF Marketplace Enrollment Snapshot for Open Enrollment 2026, using CMS data through January 15, 2026. Some of that drop reflects people priced out of the individual market entirely once enhanced subsidies ended, which is exactly the population an ICHRA contribution can reach without requiring an employer to run a traditional group plan.

Why more small employers are looking at this now

New Hampshire's rate filings aren't happening in a vacuum. The HRA Council, an industry association that aggregates anonymized enrollment data from its 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, with ICHRA-covered lives alone surpassing 500,000 for the first time at the start of 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. The same report found that more than half of enrollments, on- and off-exchange, are by employees under age 45, a younger cohort than the ACA marketplace overall.

That distinction matters for a New Hampshire employer weighing this for the first time. For most small businesses in the state, every one of whose counties qualifies for 2026, 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 with small-group rates already filed up 12.4% for 2027 and one individual-market carrier already headed for the exit. The 2019 IRS, DOL and HHS final rule that created ICHRA sets no employer-size minimum at all; a single-employee company can offer one on the same terms as a 500-person company.

How ICHRA Savings helps

None of the county math above requires talking to anyone. The savings map lets you look up any New Hampshire 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 the Manchester-area tier, the North Country tier, or a split between the two 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 carrier and 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/. A few minutes there tells you whether your New Hampshire workforce lands in the 24.4% tier, the 9.6% tier, or both.

Setting up an ICHRA in New Hampshire

New Hampshire 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 the same as any other state:

1. Pull your census by county, not by office address. A company headquartered in Manchester with field or remote staff in the North Country has a materially different savings story per location, even within one small state.
2. Check each employee's county on the savings map. A 24.4% tier and a 9.6% tier both technically "qualify," 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, whether you use the W-2, rate-of-pay or FPL safe harbor.
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 the federal ICHRA final rule, eligible employees generally need written notice at least 90 days before the plan year starts, with specific required content about the offer and its effect on subsidy eligibility.
6. Budget for onboarding support. With one carrier exiting New Hampshire's individual market for 2027, employees who have shopped the same plan for years may need guidance picking a replacement, not just first-time guidance.

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 New Hampshire workforce spans both tiers.

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 New Hampshire's 10 counties, we compare a 2026 individual-market benchmark premium, the second-lowest-cost silver plan available to a representative 50-year-old enrollee, against a small-group benchmark premium built from comparable small-group plan filings for that county's rating area. A county "qualifies" when the individual benchmark sits below the small-group benchmark; the percentage and dollar savings figures in this article are the gap between those two numbers, expressed as an annual per-employee figure at 12 times the monthly difference. The separate 2026 and 2027 rate-filing figures in this article come from New Hampshire Insurance Department and SERFF filings as compiled by ACA Signups, cross-checked against the federal Rate Review database via HealthInsurance.org, and are not reflected in the county-level qualifying dataset above, which uses the 2026 benchmark comparison described here. New Hampshire's single statewide CMS rating area is confirmed directly from CMS's own geographic rating area designation for the state.

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 by the same margin 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 New Hampshire employers actually ask