Employer coverage ยท Updated September 2026
Which funding structure fits your company?
Six ways to fund employer coverage. What each one makes possible, what it asks you to take on, and which one tends to win at your size and census.
Short answer: group size sets what's available to you, and census age sets which available option is cheapest. Under about 25 employees, most groups do best with a fully insured plan, a CHOICE Arrangement (the new federal name for an ICHRA), or a guaranteed issue, shelf-rated plan (one flat rate for everyone, regardless of age or health). Between 25 and 100, level funding usually wins. Above 100, self-funding opens levers that are structurally unavailable below it. Self-funding a 20-person group is legal, common, and usually a bad trade.
Short answer: under about 25 employees, most groups do best with a fully insured plan, a CHOICE Arrangement (the new federal name for an ICHRA), or a guaranteed issue, shelf-rated plan (one flat rate for everyone, regardless of age or health). Between 25 and 100, level funding usually wins. Above 100, self-funding opens levers that are structurally unavailable below it. Self-funding a 20-person group is legal, common, and usually a bad trade.
The menu
What are my options? The 6 ways to fund employer coverage
Six structures: fully insured, CHOICE Arrangement (formerly ICHRA), guaranteed issue shelf-rated, alternative shelf-rated through a sponsored benefit fund, level funded, and self-funded with stop-loss.
Ranked by what the employer takes on, not by which is better. The right answer depends on your census, your claims history and how much month-to-month variability your cash position can absorb.
| Structure | How it's priced | Employer keeps | Employer takes on |
|---|---|---|---|
| Fully insured | Age-rated inside the ACA 3:1 federal band, by rating area. Some states compress the band or use pure community rating | Full certainty | Nothing beyond the premium |
| CHOICE Arrangement Formerly ICHRA | You set a defined contribution (a fixed dollar amount you fund). Employees buy their own plan on the individual market | Total budget control, employee choice of plan and network | Affordability testing, employee notice, and substantiation (proof they bought coverage) |
| Guaranteed issue, shelf-rated plan | One published rate per coverage tier, the same everywhere in the country. No age rating, no census, no medical questions. Plan designs are fixed | Certainty, and immunity from a census that prices badly | Eligibility requirements, fixed plan design, no claims data |
| Alternative shelf-rated plan Additional employer participation requirements | Published rate per tier through a sponsored benefit fund, a jointly governed plan an employer joins rather than buys | Large-group pricing at small-group size | Ongoing participation and governance obligations, limited design control |
| Level funded | Fixed monthly maximum. Claims fund plus admin plus stop-loss, the insurance that caps what the employer pays on large claims. Underwritten | Surplus if claims run low, and your own claims data | Month-to-month variability inside a contractual ceiling |
| Self-funded with stop-loss | Admin plus stop-loss plus actual claims. Two attachment points, the dollar level where stop-loss starts paying: specific, per claimant, and aggregate, for the whole plan | Full surplus, full data, full plan design control | Claims volatility above the fund, cash-flow timing, and lasering at renewal |
The number most people miss
Fully insured, level funded and self-funded are not priced on the same thing. Compare them on total plan cost per enrolled employee per month, employer share plus employee share, medical and Rx only.
For level funding, compare the maximum funding rate against fully insured premium. That's the guaranteed ceiling, and it's the only apples-to-apples line. Expected cost after surplus return is a second, separate number. Comparing a premium to a projection isn't a comparison.
What each one unlocks
What does each funding structure unlock?
This is the part that changes the decision. Several of the largest cost levers in employer healthcare aren't options a fully insured employer has declined. They're structurally unavailable until the funding chassis changes, because the employer doesn't own the contract and never sees the claims.
| Lever | Fully insured | Shelf-rated | Level funded | Self-funded |
|---|---|---|---|---|
| Your own claims data | No | No | Yes | Yes |
| Pass-through pharmacy contract | No | No | Yes | Yes |
| Payment integrity on your claims | No | No | Limited | Yes |
| Reference-based pricing | No | No | No | Yes |
| Provider steerage with a funded HRA | Partial | Partial | Yes | Yes |
| Specialty drug management | No | No | Yes | Yes |
| Surplus return in a good year | No | No | Yes | Yes |
| Immunity from a bad census | No | Yes | No | No |
| Predictable fixed cost | Yes | Yes | Capped | No |
By company size
Which funding structure fits my company size?
Short answer: under 25 enrolled, fully insured, a CHOICE Arrangement or shelf-rated. 25 to 100, level funded. Over 100, self-funded with the full lever stack.
Size doesn't tell you what's best. It tells you what's on the menu. Stop-loss carriers set minimum enrollment thresholds, and those thresholds are the real gate.
| Enrolled | Realistically available | Usually comes out ahead | Why |
|---|---|---|---|
| 1 to 9 | Individual market, CHOICE Arrangement, guaranteed issue shelf-rated plan, fully insured in some states | CHOICE Arrangement or shelf-rated | Small-group participation minimums are hard to clear. Shelf rates ignore a small, older census entirely |
| 10 to 25 | Fully insured, CHOICE Arrangement, shelf-rated, level funded in some states | Depends almost entirely on average age | This is the crossover band. Young census favors age-rated. Older census favors shelf-rated |
| 26 to 50 | Fully insured, level funded, CHOICE Arrangement, PEO, shelf-rated | Level funded with a steered HRA overlay | First size where you can own claims data and still cap the downside contractually |
| 51 to 100 | Level funded, self-funded, group captive entry in some programs | Level funded, moving to self-funded | Enough claim volume for experience to start meaning something |
| 101 to 250 | Self-funded, captive, full carve-outs | Self-funded with the full lever stack | Pharmacy and payment-integrity carve-outs become worth the administrative load |
| 251 to 500 | Self-funded, group captive, direct contracting | Captive | Stop-loss spread and surplus return start to outweigh the capital commitment |
| 500+ | Everything | Captive with the full stack | Claims are credible. You're pricing your own risk, not buying someone's estimate of it |
The crossover
Age-rated or shelf-rated? Where the crossover happens
Rule of thumb: average age under 35 usually wins on age-rated. Average age over 45 usually wins on shelf-rated. In between, model both.
Age-rated means the premium changes with each employee's age. Shelf-rated means one published rate per coverage tier, identical for a 24-year-old and a 64-year-old, anywhere in the country.
ACA small-group premiums are age-rated. Federal rules allow up to a 3:1 spread between the oldest and youngest adult rate, so a 64-year-old can be priced at three times a 21-year-old for the identical plan. A handful of states compress that band further, and two use pure community rating.
Shelf-rated plans work the opposite way. A short list of coverage tiers, one published rate for each, no age rating, no census collection and no medical questions. That produces a predictable crossover.
| Census profile | Age-rated small group | Shelf-rated plan | Typical outcome |
|---|---|---|---|
| Average age under 35, few dependents | Priced near the bottom of the 3:1 band | Pays the same flat rate as everyone | Age-rated wins, often by a wide margin |
| Average age 35 to 45 | Mid-band | Flat | Close. Model both |
| Average age 45 to 55 | Upper-band, climbing fast | Flat | Shelf-rated often wins |
| Average age 55+ | Near the top of the band | Flat | Shelf-rated usually wins, sometimes substantially |
| Known high-cost claimant | Community-rated pool absorbs it, but renewals reflect the block | Guaranteed issue, no medical underwriting | Shelf-rated removes underwriting risk entirely |
Why this matters for older and less healthy groups
A 12-person landscaping company with an average age of 57 and two diabetics is expensive to insure in the age-rated market and hard to underwrite for level funding. A shelf-rated plan doesn't ask. It's the same rate it charges a 24-year-old.
That's not a loophole. It's what happens when a plan prices a national pool instead of your twelve people. Eligibility rules apply and not every employer qualifies.
The reverse is just as true. A 12-person design studio with an average age of 29 is subsidizing that same national pool, and will almost always do better age-rated.
By industry
Which funding structure fits my industry?
Industry is a proxy, and it's worth saying plainly: census age and dependent take-up predict the answer better than industry does. Two restaurants with 40-year and 26-year average ages land in different places. Use the table as a starting hypothesis, then check the census.
| Industry | What drives the decision | Structure to model first | Highest-value overlay |
|---|---|---|---|
| Restaurant and QSR | Turnover above 75%, variable hours, low take-up rate | CHOICE Arrangement or shelf-rated | $0 copay formulary, virtual primary care |
| Construction and trades | Older skew, injury exposure, mixed W-2 and 1099 | Shelf-rated, or level funded if the census underwrites | Musculoskeletal program, steerage |
| Home health and senior care | Low wage, high turnover, heavy behavioral health need | CHOICE Arrangement | $0 copay formulary, behavioral health access |
| Staffing | Extreme turnover, ACA measurement period complexity | CHOICE Arrangement with a minimum value plan, one meeting the ACA 60% coverage standard | Front-door navigation, eligibility automation |
| Trucking and logistics | Older, dispersed geography, high chronic burden | Shelf-rated with a national network | $0 copay formulary, virtual primary care, chronic condition management |
| Professional services and tech | Younger, healthier, high benefit expectations | Level funded | Steered HRA overlay so a leaner plan feels richer |
| Dental, veterinary, medical practices | Small headcount, owner age dominates the rate | Shelf-rated if the owner is older, level funded if not | Steerage, specialty Rx |
| Manufacturing | Stable workforce, MSK heavy, high family-tier enrollment | Level funded, then self-funded at scale | MSK, steerage, payment integrity |
| Nonprofit and social services | Budget-constrained, older, mission-driven retention | CHOICE Arrangement or level funded | $0 copay formulary, behavioral health |
| Multi-unit retail | Part-time mix, multiple states, multiple rating areas | CHOICE Arrangement | Rating-area-aware contribution design |
Questions
Health plan funding questions, answered
The questions employers ask most often about funding structures, stop-loss and cost levers.
Why shouldn't a 20-person company self-fund?
What does โshelf-ratedโ mean?
What is lasering, and why should I ask for a no-laser provision?
ICHRA was renamed. What is a CHOICE Arrangement?
What group size is level funding actually available at?
Why is provider steerage worth building a plan around?
How does a $0 copay formulary save the employer money?
Can an older or less healthy group get coverage that doesn't price their health?
How does CHOICE Arrangement (ICHRA) affordability work?
What's the difference between a level funded maximum rate and its expected cost?
Do the savings from different cost levers add up?
Do I have to disrupt employees or cut anything to lower cost?
In practice
What does this look like in practice?
About this example
The company below is illustrative, drawn from the patterns in real engagements, with identifying details removed and figures rounded. It is not a specific client and not a projection of your results.
A 62-employee specialty manufacturer, average age 44, 58% enrolled in a dependent tier, currently fully insured on a PPO. Total plan cost sits above the published benchmark for their size and region.
They move the chassis to level funded at renewal. The maximum funding rate lands below the renewal premium, which is the day-one number. Because they now own the contract and the claims data, three levers that were unavailable to them open at the same time: a pass-through pharmacy arrangement, a steered out-of-pocket HRA that zeros member cost at high-performing providers, and a musculoskeletal program aimed at their highest-frequency claim category.
Employees move to a leaner plan design on paper and pay less out of pocket in practice, because the HRA covers the gap where they're steered. Nobody lost coverage, nobody lost a job, and the employer's budget dropped on the first invoice.
Typical results across engagements of this shape run in the range of 15% to 25% of plan cost, with the full lever stack reaching up to 20% to 30% at larger sizes. Actual results depend on census, claims history, enrollment and which levers the structure supports. Savings ranges from different levers are not additive.
Work out where you actually stand
Three free tools, all built from filed 2026 rate data. No form, no login.
Where does my cost sit today?
Your percentile against filed small group premiums for your state, from 2026 rate filings. All 50 states plus DC.
What would the individual market cost?
Lowest-cost Silver by county and age, with household totals for spouse and children. 3,137 counties.
What does a fixed budget look like?
CHOICE Arrangement, formerly ICHRA. Classes, affordability, and what can be bundled on top at $0 copay.
Fifteen minutes, your current rate
If you could change one thing about your health plan without changing your budget, what would you change?
Most employers have never been shown what their structure makes possible.
Methodology and important disclosures
What this page is. An educational comparison of funding structures available to employers. It is not a quote, an offer of coverage, a recommendation of any specific plan or carrier, or advice about what is suitable for your organization. Suitability depends on your census, claims history, cash position and risk tolerance, none of which this page knows.
Availability. Not all structures described here are available in all states, at all group sizes, or to all employers. Guaranteed issue shelf-rated programs and sponsored benefit fund programs carry eligibility conditions and participation requirements, and are not available to every employer. Availability is determined by the program, not by this page.
Ranges. All savings figures are stated as ranges and reflect outcomes observed across engagements, rounded. They are not guarantees and not projections of your results. Savings ranges from different levers are not additive. Statements about retention, attraction, absenteeism and workplace outcomes describe the mechanisms by which these programs are designed to work. They are not quantified performance claims and no specific result is promised.
Program components. Bundled care components described on this page are available a la carte and vary by employer, state, group size and eligibility. Availability, covered services, visit terms and any utilization or clinical-appropriateness limits are set by each program and its published terms, not by this page. Where visits are described as unlimited, that reflects no per-member visit cap under the program terms and remains subject to clinical appropriateness and the program's own conditions of use. The medication count reflects the current formulary and is subject to change.
Member discounts. Legal, identity theft, cyber, caregiver and dependent care, pet care and household service benefits are discount and membership programs, not insurance. They do not pay providers, they do not coordinate with a health plan, and availability varies by state and by program.
Benchmarks. Group premium benchmarks derive from the KFF Employer Health Benefits Survey. Individual market data derives from CMS Public Use Files. Trend projections derive from published reports by Aon, Mercer and PwC. Each is cited as of its publication date and restates national or regional averages, not your market.
Fixed indemnity and supplemental products. Accident protection and any supplemental, hospital indemnity or fixed indemnity products referenced on this page or elsewhere on this site pay a fixed amount based on a covered event rather than on medical cost. They are not major medical coverage, are not minimum essential coverage, and are not a substitute for comprehensive health insurance.
Terminology note. CMS and the SBA renamed the individual coverage HRA the CHOICE Arrangement on September 3, 2026. That was an agency terminology change, not a statutory one, and the underlying ICHRA regulations are unchanged. Last reviewed September 2026. Benchmarks refresh annually when KFF publishes, typically in October.