Zorro Open Enrollment 2026 Analysis: Consumer Choice in Action

When Zorro set out to build a better ICHRA experience, our mission was clear: make it easy for employees to choose health coverage that actually works for their unique needs.

Not everyone was convinced. Skeptics argued that employees couldn't handle the complexity, that they'd make poor decisions without employer guidance, that consumer-directed healthcare was a nice theory that would fail in practice.

Our 2026 open enrollment data tells a different story.

Last year definitely tested the model. Enhanced ACA subsidies expired. Premiums jumped 26% nationwide. But instead of chaos, we saw something encouraging: employees across 50 states plus Washington, D.C. made thoughtful, diverse choices that reflected their actual needs — not necessarily what brokers or employers assumed they wanted.

Our analysis of Zorro’s 2026 open enrollment data — representing employees across 50 states plus Washington, D.C. — reveals a range of findings that might challenge conventional wisdom about consumer-directed healthcare:

1. Employer investment drove adoption - Employers who cover 75% or more of premiums tend to see much higher enrollment rates. In other words, ICHRA is most impactful as a strategic investment instead of a cost-cutting exercise.
   
2. Employees made diverse, informed choices - They selected plans from more than 100 carriers, and 61% chose options outside the five most commonly selected in this dataset, with preferences spread across metal tiers and network types.
   
3. Decision support enabled confident selections - 84% of employees were able to select their plans without accessing live support, up from 75% in 2025.

The bottom line: The skeptics were wrong. Pair meaningful employer investment with empowered choice and smart decision support, and ICHRA works.

Employee population analysis

I. Employer investment drove adoption

Employer contribution level impacts enrollment rate more than anything else. Our data reveals a clear threshold: employers covering 75% or more of premiums see dramatically higher enrollment rates. Below that, employee engagement levels drop off significantly. This pattern held across all employers in our dataset, proving ICHRA makes the most impact with employees when it’s treated as strategic investment — not minimum viable compliance.

60% of enrolled employees have 75%+ of their premium covered

These aren't token contributions designed to meet minimum compliance thresholds. Nearly 6 in 10 enrolled employees have employers covering three-quarters or more of their premium.

Employers covering 75%+ of premium see 65-74% enrollment vs 40% for others

The pattern is stark. When employers cover between 1-74% of premiums, roughly 60% of employees either waive or miss the deadline. Once coverage reaches 75%, completion jumps to 65-74%.

The "Deadline Passed" data reveals something critical: When employers offer 0% coverage, over half of employees (54%) don't even engage — they simply let the enrollment window close. This isn't active decision-making; it's disengagement driven by unaffordable options.

In contrast, virtually no one (<1%) misses the deadline when employers cover 75%+ of premiums. Employees engage, evaluate options, and make decisions — even if some ultimately waive coverage.

The 75% coverage threshold represents a tipping point

Below 75% coverage, employees face meaningful out-of-pocket costs that drive disengagement. Above 75%, coverage becomes accessible enough that nearly two-thirds complete enrollment.

At 100% employer coverage, nearly three-quarters of employees (74%) enroll, with only 26% actively waiving — and virtually zero missing the deadline due to inaction.

II. Employees made diverse, informed choices

To better understand how ICHRA enables genuine consumer choice, look no further than employee decision data. If employees were defaulting to familiar brands, following employer nudges, or making random selections, we'd see concentration around a few dominant choices. Instead, we observe distribution across every dimension analyzed.

Metal tier recalibration

We saw a significant shift in how employees chose their metal tiers. Gold dropped 15 percentage points (55% → 40%). Bronze jumped 5 points (25% → 30%). That's a notable change in how people are weighing monthly premiums against potential out-of-pocket costs.

But here's what's not happening: a race to the cheapest option. Nearly two-thirds of employees (64%) still chose Silver, Gold, or Platinum. Four in ten stuck with Gold coverage.

What we're seeing is nuance. Some employees with lower healthcare needs saw Bronze's lower premiums as smart economics. Others prioritized comprehensive coverage and stayed with Gold or Silver. Different circumstances, different choices.

That's exactly what ICHRA is supposed to enable — and the metal tier distribution proves employees are using that flexibility thoughtfully.

HMO vs PPO: Conventional wisdom, flipped on its head

HMO selection jumped from 38% to 53% — a 15-point increase. Meanwhile, PPO barely budged, moving from 28% to 31%.

This may come as a surprise with what most people know about traditional plan design. Brokers have historically pushed hard for more PPO options, assuming employees wanted the broadest possible networks. Carriers listened and built PPO products. But not as many employees ended up choosing PPOs as brokers anticipated.

Why HMOs may be preferred by employees:

• Better value. HMOs deliver comprehensive coverage at lower premiums. When you're spending your own dollars (even if reimbursed), that math matters.
• Personalized networks. Employees don't need access to every doctor in America. They need access to *their* doctors. With ICHRA, each family picks the carrier that covers their specific providers. Broader isn't always better.
• Real-world priorities. Given the choice, most employees opted for predictable costs over theoretical network flexibility they'd likely never use.

The takeaway: Employees make rational choices when you give them the tools and let them decide. What they choose might surprise you — but it's what actually works for their households.

Carrier distribution: 100+ selected, with no dominant player

The carrier selection data provides clear evidence of genuine consumer choice. Employees selected from over 100 unique individual market carriers, with no single player dominating.

Even Ambetter, the leading carrier, captured fewer than 1 in 7 enrollments. The top five carriers combined for just 39% of selections, meaning 61% of employees chose plans from the broader long-tail of available carriers.

The top 10 includes a mix of national brands (Ambetter, Anthem, UnitedHealthcare, Oscar, Kaiser) and regional or state-specific carriers like St. Luke's Health Plan in Idaho and PacificSource in the Pacific Northwest.

What’s important to clarify: Many of the selected carriers are regional or state-specific arms of larger systems. For example, within our top 10 most commonly selected carriers, we see Wellmark BCBS of Iowa and BCBS of North Carolina. These carriers are part of the broader Blue Cross Blue Shield ecosystem but operate independently, with their own networks, pricing, and consumer footprint.

Even so, no single carrier or system dominated. This means that employees aren't defaulting to the biggest brand they recognize. They're evaluating which carrier actually covers their doctors, offers competitive pricing, and fits their specific needs. Even smaller regional carriers can compete effectively when individual consumers make the choice.

And here's the interesting part: when carriers have to earn business directly from consumers (rather than winning over a benefits committee), they compete on things like customer service and network quality. And the playing field levels: Market share becomes about value, not just name recognition or broker relationships.

Carrier loyalty held strong (despite 26% premium increases)

Average premiums jumped 26% in 2026. You'd expect employees to shop aggressively for savings. Yet 64% of returning employees stuck with the same carrier they had the year before.

Here's the breakdown: 37% kept their exact same plan. Another 27% stayed with their carrier but switched to a different plan — maybe dropping from Gold to Silver, or moving from a PPO to an HMO to manage the premium increase. Only 31% switched carriers entirely.

Why the loyalty? A few things could be driving it:

• Employees who had good experiences (smooth claims processing, responsive customer service, solid provider networks) may have been willing to pay a bit more rather than start over with an unknown carrier.
  
• Provider continuity matters. If your family has established care relationships, especially for chronic conditions, switching carriers (and potentially switching doctors) is a bigger deal than absorbing a premium increase.

That 27% who switched plans within their carrier? They may have recognized the premium increase as a chance to optimize — adjusting their coverage level while keeping their doctors and their carrier relationship intact. Cost-conscious, but strategic about it.

As for the 31% who switched to a different carrier, the question remains: Were they primarily chasing cost savings, or were there other factors at play? Of those who switched, 17% saw their premium decrease, while 83% saw their premium increase. At first glance this seems counterintuitive (why would someone switch carriers and accept an increase?) 

But consider the broader market context: premiums increased an average of 26% nationwide in 2026. In other words, it’s possible that they may have avoided steeper increases had they stayed with the same carrier. They could have also made the decision to change based on other factors, such as better network access, lower out-of-pocket costs, or broader coverage.

III. Decision support enabled confident choices

One of the most persistent objections to ICHRA has been the complexity argument: "Employees can't handle choosing their own health insurance. They'll make bad decisions, get overwhelmed, and blame their employer." This assumes healthcare decision-making requires professional expertise that typical employees lack. Our 2026 data thoroughly refutes this concern.

Self enrollment increased 9 points year-over-year

Eighty-four percent of employees selected their health plan during open enrollment without ever accessing live support. This represents a 9-percentage-point increase from 2025's already-impressive 75% self-enrollment rate.

This isn't employees settling for suboptimal coverage or making rushed decisions. It reflects the effectiveness of AI-powered decision support tools that translate complex insurance concepts into understandable trade-offs.

How Zorro makes confident self-selection possible

The high self-enrollment rate stems from several technological capabilities working in concert:

• Personalized recommendations: Zorro's proprietary AI analyzes thousands of data points — including age, location, household size, provider preferences, and prescription needs — to recommend the 3-5 plans most likely to meet each employee's needs.
• Plain-language explanations: Instead of insurance jargon (actuarial value, coinsurance, formulary tiers), employees see clear descriptions of what plans cover, how networks work, and what costs they can expect based on their anticipated utilization.
• Trade-off visualization: Interactive tools show how choosing a lower premium impacts deductibles and out-of-pocket maximums. Employees can see, for example, that saving $50 monthly on premiums might mean paying $2,000 more if they need surgery — helping them understand the implications before deciding.
• Provider and pharmacy matching: Employees can verify that their current doctors and medications are covered before selecting a plan, reducing uncertainty and post-enrollment surprises.
• Conversational AI chat bot: Employees can ask questions in plain language and get instant, personalized answers about plan options, coverage details, and costs. The AI can guide employees through complex scenarios without requiring them to navigate insurance terminology or wait for a human specialist.

When they needed it, 16% chose to access human support

Some employees just prefer talking to a person. And that's completely valid.

Sixteen percent of employees chose to speak with a Zorro specialist during their enrollment. Not necessarily because their situation was complex — though some were navigating chronic conditions, multi-state families, or unusual provider networks. Often, they just wanted the reassurance of talking through their options with someone who could answer questions in real time.

That's why Zorro combines AI-powered tools with human expertise. Most employees feel confident navigating with the platform alone. But for anyone who wants personalized guidance — whether their situation is objectively complex or they simply prefer human interaction — our specialists are there to help.

It's not about one approach being better than the other. It's about meeting people where they are and giving them the support they need to feel confident in their choice.

Strategies for the road ahead

Our 2026 OE data doesn't just tell us what happened when ICHRA was offered to employees across the country — it shows us what works. For brokers and HR leaders planning 2027 open enrollment or considering ICHRA for the first time, here are the strategic implications to keep in mind.

1. Lead with investment.

High employer contributions aren’t nice-to-have — they’re the determining factor. Generous contributions = stronger enrollment = happier teams.

2. Expect smarter shoppers.

Between the shifts in metal tiers, carrier loyalty rates, and the 84% self-selection rate, there are clear signs that when they’re given the right tools and guidance, employees are able to make sophisticated decisions for their own unique needs — exactly what ICHRA was built for.

3. Double down on decision support.

Even if employees can choose for themselves, that doesn’t mean they should do it completely alone. Zorro’s 84% self selection rate is evidence that tech-led decision support works. When people understand their options, they make better choices.

4. Prove value beyond cost.

Employers need better metrics for ICHRA success beyond "we spent less." Instead, consider the full picture:

• Employee satisfaction scores
• Retention rates year-over-year
• Support utilization patterns
• Carrier diversity
• Coverage continuity

These indicators show whether ICHRA is delivering genuine value or just shifting costs to employees.

The bottom line for 2027 (and beyond)

Our 2026 data validates that ICHRA works best when three conditions align:

1. Employers invest strategically (75%+ premium coverage drives engagement)
2. Employees receive effective support (AI tools + human assistance enable confident decisions)
3. Expectations match reality (ICHRA isn't right for everyone, but it's right for more than skeptics assumed)

The conversation has evolved from "Does ICHRA work?" to "How do we make it work well?" That shift — from existential doubt to operational optimization — signals a market moving from early adoption toward mainstream maturity.

For brokers and HR leaders approaching 2027 planning, the opportunity is clear: ICHRA isn't a panic button for unsustainable renewals. It's a strategic benefits evolution that, when implemented thoughtfully, can serve diverse employee needs better than one-size-fits-none group insurance.

If rising group premiums, multi-state complexity, or the need for modern benefits tech sounds familiar, you're not alone. The employers in this analysis faced the same challenges — and found that ICHRA delivered results. Zorro's team can show you how a similar approach might work for your organization. Contact us to learn more.