ICHRA in Sandusky, Ohio 2026: Erie County 63%

Does ICHRA beat small group in Sandusky, Ohio?

Yes, and by the widest margin of any Ohio county we've covered so far. 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 Erie County, the Ohio county that contains Sandusky, the 2026 individual-market benchmark premium runs an estimated 63.0% 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.

That 63.0% ties for first among Ohio's 88 qualifying counties, above the statewide qualifying average of 54.9% and above what Cincinnati (Hamilton County, 62.3%), Columbus (Franklin County, 59.6%), and Toledo (Lucas County, 57.0%) show for 2026. What makes Erie worth its own guide isn't only the headline number — it's an economy that runs on Lake Erie tourism and a seasonal, part-time-heavy workforce, which creates a specific, common problem for the small businesses that supply and surround that industry: getting a small-group policy issued at all.

Of the 1,309 counties nationwide in our dataset, 88 are in Ohio, and every one of them clears the $100-a-month gap we use as the floor for including a county at all. Erie clears it by more than nine times over, at $928.76 a month. The real question for a Sandusky-area employer isn't whether the county "qualifies" in the abstract — every Ohio county does. It's whether the structure of ICHRA actually solves the specific problem a seasonal-economy employer runs into with group coverage, which is what the rest of this guide works through.

Why Erie County ties for Ohio's highest percentage

A statewide average tells you almost nothing about any one county, and Erie is the clearest proof of that on this site, from the opposite direction of a county like Summit (Akron), which carries Ohio's narrowest spread. Ohio's 88 qualifying counties average 54.9% savings, and the distribution runs from the low 30s up into the low 60s. Erie sits at the very top of that range — tied, not alone. Huron, Ottawa, Sandusky, Seneca, and Wyandot counties carry the exact same 63.0% figure, because premiums are set by rating area, a geographic zone insurance regulators use to price plans, and all six of these counties sit inside the same one.

The next-closest counties aren't far behind, which is worth naming so the number doesn't look like an outlier: Morrow County comes in at 62.7%, and the Cincinnati-area rating area that includes Hamilton, Butler, and Warren counties sits at 62.3%. Erie's tie for first is real and it's close, not a runaway, and that's a more honest way to describe a dataset than pretending one county stands alone at the top.

The reason isn't anything specific to Sandusky's tourism economy or its workforce composition — it comes down to how carriers filed their 2026 rates for this specific rating area. The individual market benchmark here is $544.80 a month, one of the lowest individual benchmarks of any Ohio rating area, while the small-group benchmark is $1473.56 a month, near the middle of the state's range. A rating area with an unusually low individual benchmark next to an ordinary small-group benchmark produces the widest percentage spread, which is exactly Erie's situation for the 2026 plan year.

The seasonal, tourism-heavy economy behind the real problem

Sandusky's local economy is built around Lake Erie and Cedar Point, one of the best-known amusement parks in the country, and that shapes the local labor market in a way a generic "Ohio saves X%" headline never captures. Per the U.S. Bureau of Labor Statistics' Quarterly Census of Employment and Wages (QCEW), Erie County's private-sector employers reported an annual average of 31,368 jobs across 1,942 establishments in 2025. Within that total, arts, entertainment and recreation employers (NAICS sector 71) accounted for 3,407 jobs across 80 establishments, and accommodation and food service employers (NAICS sector 72) accounted for another 5,610 jobs across 281 establishments — together, roughly 29% of the county's private employment, for the 2025 annual average, the most recent full year on record. Manufacturing, the county's other major sector, employed 5,398 people across 113 establishments in the same period, at a considerably higher average annual pay of $72,736 versus $25,082 in accommodation and food service.

One detail from that same BLS dataset says as much as the numbers that are published: the specific line item for amusement parks and arcades (NAICS 7131), the category Cedar Point itself falls into, is suppressed in Erie County's 2025 QCEW release, flagged with a nondisclosure code. The Bureau withholds county-industry figures when so much of an industry's local employment sits inside one or two employers that publishing the number would effectively disclose that employer's headcount. That's not a data gap this article can fill with a guess — it's a real signal, straight from a federal statistical agency, that one seasonal employer dominates a meaningful share of Erie County's private workforce.

None of that is a knock on Sandusky's economy. It's the setup for the actual pain point this article answers. A seasonal, seven-month tourism season means a local labor market full of part-time workers, workers who hold a second job elsewhere in the off-season, workers already covered through a parent's or spouse's plan, and workers who churn out before a plan year ends. For the small machine shops, marinas, charter-fishing operators, restaurants, and professional-services firms that orbit that tourism economy rather than run it, that labor mix creates a specific, recurring problem when they try to offer their own group health coverage — the subject of the participation-minimum section further down.

Why 2026 and 2027 renewals keep landing high

For the Sandusky-area employers who do already carry a small-group plan, the renewal letter has been getting heavier for two straight years, and that's not a local quirk. Nationally, small-group insurers filed a median proposed premium increase of 14% for the 2027 plan year, across 295 insurers filing in all 50 states and the District of Columbia, according to the Peterson-KFF Health System Tracker's August 6, 2026 brief. Fifty-nine percent of those small-group insurers proposed increases between 10% and 20%, the same brief found — this isn't a handful of outlier carriers, it's the median.

The pressure isn't limited to small group. KFF's own tracking of ACA marketplace competition found that the average number of insurers participating per state fell from 9.6 in 2025 to 9.0 in 2026, and that the number of counties served by only a single ACA issuer jumped from 93 in 2025 to 165 in 2026 — a shift KFF ties largely to CVS Aetna's exit from 17 states and other insurer departures following the expiration of enhanced premium tax credits at the end of 2025.

None of that changes the underlying mechanic that makes ICHRA work in a county like Erie: what matters isn't whether either market's prices went up in isolation, it's whether individual rates rose relative to small-group rates in the same county and the same rating area. Erie's rating area's small-group carriers have been filing real increases, and the individual market hasn't closed that gap here or in any of the five other counties that share this rating area.

How an ICHRA (now also called CHOICE) actually works

Before the Erie County numbers mean anything, it helps to be precise about what's being compared, since most of the confusion around ICHRA comes from skipping this step.

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 at 84 Fed. Reg. 28888 on June 20, 2019, effective August 19, 2019, and 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 fifteen different households; the employer is funding a budget, and the employee is doing the shopping.

Worth naming directly, since it's a live source of confusion: 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, since that's still the term used in the regulations themselves, and the two names refer to the identical legal arrangement. If you want the fuller story on where the "CHOICE" name came from, including the separate legislative proposals that predate this naming update, see our CHOICE Arrangement explainer.

The comparison behind every number in this article rests on two specific prices for a given county and rating area. The individual-market benchmark premium is the second-lowest-cost silver-level plan available in that rating area to a representative 40-year-old enrollee. "Silver" refers to 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 that same rating area. 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 employer can trigger a penalty tied to the employer mandate, the ACA requirement that applies to ALEs (applicable large employers, generally 50 or more full-time-equivalent employees). Smaller, non-ALE employers aren't subject to that mandate at all, which matters here: most of the small tourism-adjacent and manufacturing employers described above are well under that threshold.

One structural piece is often misunderstood: an employer can define different employee classes — for example, full-time versus part-time, or seasonal versus year-round — and offer different benefits to each class, subject to federal minimum-size rules for some class types. What an employer cannot do is offer the same class of employees a choice between ICHRA and a traditional group plan; it's one or the other, per class, not both at once for the same people.

Erie County's rate spread, in dollars

Here is the actual 2026 benchmark comparison for Erie County, the county that contains Sandusky, Huron, Vermilion, Berlin Heights, and Kelleys Island. The individual-market benchmark premium is $544.80 a month. The small-group benchmark premium, built from comparable small-group plan filings for the same rating area, is $1473.56 a month. That's a gap of $928.76 a month, or $11,145 a year, per employee, an estimated 63.0% in favor of the individual market — tied for the widest percentage of any qualifying county in Ohio.

At 75K residents, Erie is a mid-sized qualifying county by Ohio standards — smaller than Franklin (Columbus) or Cuyahoga (Cleveland), but with the widest percentage spread on the board. A narrower spread on a large population and a wide spread on a smaller one can add up to comparable aggregate dollars across a metro's employers, which is the same lesson the Akron guide draws from the opposite direction; Erie just gets there with the largest percentage rather than the largest headcount.

Notice that Erie's 63.0% sits above every county on that population list, including Hamilton (Cincinnati) at 62.3% and Franklin (Columbus) at 59.6%, despite Erie being one of the smaller counties in the state. That's the lesson every county-level dataset teaches: population size and savings percentage don't move together, and a statewide "Ohio saves X%" headline would hide real variation between one county and the next. Check your own county, not a regional average, before you model a rollout.

See the full Ohio savings breakdown for every qualifying county, or the national savings map to look up a specific county by name.

The five counties that price identically with Erie

Erie County doesn't stand alone. Huron County (59K residents, home to Norwalk), Ottawa County (40K residents, home to Port Clinton and the Lake Erie islands), Sandusky County (59K residents, home to Fremont), Seneca County (55K residents, home to Tiffin), and Wyandot County (22K residents, home to Upper Sandusky) all sit in the same marketplace rating area as Erie and carry the exact same 2026 benchmark comparison: a $544.80 individual benchmark against a $1473.56 small-group benchmark, the same 63.0% spread and the same $11,145 estimated annual savings per employee. Combined, those six counties hold an estimated 310K residents, so a Sandusky-based employer with staff commuting in from Fremont, Port Clinton, Norwalk, Tiffin, or Upper Sandusky doesn't need to run a separate calculation for each location — the same math applies across the whole rating area.

Ottawa County is worth calling out on its own, since it's already come up on this site once before: our Toledo, Ohio guide references Ottawa as a neighboring rating area with a wider spread than Lucas County, without spelling out the exact figure. This article is that figure, in full: Ottawa carries the identical 63.0% comparison as Erie, because they share the same rating area.

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

Why participation minimums bite hardest in a tourism county

Small-group health insurance isn't sold to individual employees one at a time; it's underwritten as a pool, and carriers typically require a minimum share of a company's eligible employees to actually enroll before they'll issue the policy at all. That's a participation minimum, and it's a real reason a company can want to offer group coverage and still fail to get a policy issued — not because the price is wrong, but because not enough employees signed up. We've written a full breakdown of exactly how that calculation works in our participation requirements guide.

The mechanic matters more in a place like Sandusky than in a typical metro, for a structural reason the BLS data above makes concrete. A workforce concentrated in seasonal amusement-park and hospitality jobs tends to include a higher share of part-time staff, workers holding a second job in the off-season, teenagers and college students still on a parent's plan, and spouses already covered through a partner's year-round employer. Any of those situations can push a small employer's eligible-but-declining share high enough to fail a carrier's participation math, even when every employee technically has coverage somewhere.

An ICHRA (or CHOICE Arrangement, per HealthCare.gov's current naming) sidesteps the mechanic entirely, and the current federal guidance on this point is specific rather than a blanket claim. Per HealthCare.gov, if an employer offers a CHOICE Arrangement on its own, with no traditional group plan running alongside it, there is no participation-percentage requirement at all. 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 they're both in use; they don't apply at all to an employer offering only a CHOICE Arrangement.

A ten-person Sandusky-area company where six employees are seasonal staff already covered through a parent's or spouse's plan can still offer all ten of them an ICHRA. The four who need it can use it, and the six who don't aren't required to enroll in anything to make the arrangement work — there's no carrier-side percentage to clear, because each employee's reimbursement is a separate arrangement funding their own individual-market plan choice, not a pooled insurance product.

A worked example for a Sandusky-area employer

Here's what the Erie County numbers look like applied to a real headcount. Assume a 15-employee Sandusky-area company — a marina, a restaurant group, or a small manufacturer — currently renewing a small-group plan priced at this year's Erie County benchmark.

The same arithmetic scales down cleanly to the kind of company this article opened on: a six-person charter-fishing or marina business near Sandusky Bay that couldn't hit a carrier's group participation minimum because most of its crew is seasonal. That company could fund an ICHRA at the $544.80 individual benchmark and offer a real, tax-free benefit for about $ 3269 a month in total contributions, or roughly $ 39,226 a year for the whole company — offered to every eligible employee regardless of how many of them already have coverage through a parent's or spouse's plan, since there's no enrollment percentage to clear.

At the other end of the size range, a 55-employee Sandusky-area manufacturer crosses into ALE territory under the employer mandate, which changes the calculus without changing the underlying county math. The same Erie County 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 an employer-mandate penalty. That's not a reason to avoid ICHRA at 55 employees; it's a reason to model the affordability test before setting a contribution amount, which our eligibility guide walks through in detail.

How ICHRA adoption is actually growing

Sandusky's numbers sit inside a national adoption trend that keeps compounding. The HRA Council's fifth annual report, Growth Trends for ICHRA & QSEHRA, Vol. 5 (released August 12, 2026, aggregating enrollment data from member administration platforms through January 31, 2026), found that ICHRA-covered lives surpassed 500,000 nationally at the start of 2026, spread across more than 20,000 U.S. businesses now offering ICHRA or QSEHRA. Adoption among applicable large employers (ALEs) more than doubled year over year, the fastest-growing segment in the report.

The number that matters most for the Sandusky-area employer this article opened on — the marina, the charter-fishing operator, the small restaurant group that couldn't get a group quote to go through: over two-thirds of small businesses offering ICHRA had previously offered no health coverage options at all, and 93% of small employers newly adopting QSEHRA in 2026 had never offered coverage before. For most small Erie County businesses, the realistic comparison usually isn't "ICHRA versus our current group plan." It's "ICHRA versus offering nothing, or versus a group plan we couldn't even get issued," which is a much easier case to make than it sounds.

Setting up an ICHRA in Erie County

Ohio does not layer state-specific ICHRA rules on top of the federal framework. The same IRS, Department of Labor and HHS final rule that governs ICHRA everywhere applies here, and the setup sequence is the same one that applies in any other state. What determines whether a Sandusky-area rollout goes smoothly:

1. Pull your census by county, not by office address. A company headquartered in Sandusky with staff living in Huron, Ottawa, Seneca, or Wyandot County shares the same rating-area numbers, but confirm each employee's actual home county rather than assuming.
2. Check whether you're offering ICHRA alone or alongside a group plan. That decision determines whether any class-size minimum applies at all.
3. 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.
4. Define employee classes carefully, if you use them. A seasonal-versus-year-round split is a legitimate class distinction, but class rules carry minimum-size requirements when paired with group coverage.
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. Seasonal employees who have never shopped the individual marketplace on their own need guidance, once, at enrollment.

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 rating area. 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 "qualifies" for our 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.

Erie County's population figure (75K) comes from the same underlying county dataset used across the site. The employment figures in the seasonal-economy section — 31,368 total private jobs, 3,407 in arts, entertainment and recreation, 5,610 in accommodation and food service, and 5,398 in manufacturing — come from the U.S. Bureau of Labor Statistics' Quarterly Census of Employment and Wages, Erie County, Ohio (area code 39043), 2025 annual averages, a separate federal dataset from our own county premium comparison. The national small-group and insurer-participation figures (Peterson-KFF and KFF), the IRS affordability percentages (Rev. Proc. 2025-25 and 2026-26), the HRA Council adoption figures, 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 county that qualifies for 2026, even at the top of the state's range, is not guaranteed to qualify — or to keep its current percentage — for 2027 if a carrier enters or exits that market.

Questions Sandusky-area employers actually ask