Home / Groups / 2–49 employees

Covering a team of 2–49

You have more ways to cover a small team than anyone’s told you — and the default is usually the priciest one on the shelf. Every route, explained.

This page lays out every route in detail — how each one works, who it's built for, and the trap door in each. There's no single "best" plan for a small group. The right answer depends on three things: how healthy your people are, how much year-to-year risk you can stomach, and which state you're in. We'll come back to all three.

One thing you don't have at this size is a legal requirement. The ACA's employer mandate only kicks in at 50 full-time-equivalent employees, so a business under that line isn't required to offer coverage at all. Most still do — it's table stakes for hiring — but you're doing it by choice, which means you get to be strategic about it.

First, what "small group" actually means (and why your state matters)

"Small group" is a regulatory category, not just a description. Federally, it means an employer with 1 to 50 employees. A few states stretch the definition to 1 to 100 — as of 2026, that's California, New York, and Vermont (Colorado used to be on that list and rolled back to 50 for 2026). The size band matters because small-group plans come with consumer protections that large-group plans don't:

Guaranteed issue. A small-group carrier can't turn your business down or exclude a sick employee. If you apply for a fully insured small-group plan, they have to sell it to you.
Adjusted community rating. Your premium can only vary by a handful of factors: the employees' ages (capped at a 3-to-1 spread between oldest and youngest adult), your geographic area, tobacco use (capped at a 1.5-to-1 surcharge), and family size. What a carrier can't do is look at your group's medical history and jack up the rate because someone had a heart attack. Everyone in the small-group pool is priced off the same community, not off their claims.
Essential health benefits. Fully insured small-group plans have to cover the ACA's core benefit categories — hospitalization, prescriptions, maternity, mental health, preventive care, and the rest.

Now the state wrinkles, because this is where owners get surprised:

New York and Vermont go further and ban age rating entirely in small group — a 25-year-old and a 60-year-old at the same company pay the same rate. That flattens costs for older workforces and raises them for young ones.
Tobacco surcharges are prohibited in several states (including California, Massachusetts, New Jersey, New York, Rhode Island, and Vermont), so the 1.5-to-1 tobacco factor simply doesn't apply there.
Massachusetts merges its individual and small-group markets into one risk pool, which changes the math again. (Vermont did too until it split the markets back apart effective January 1, 2026.)

Keep these in mind as you read the options below. A funding choice that's brilliant in Texas can be pointless in New York, and vice versa.

Fully insured — the default, for better and worse

This is what most people picture when they think "company health plan." You choose a plan from a carrier, you pay a set premium every month, and the carrier is on the hook for the claims. If your team has a catastrophic year, your cost doesn't move until renewal — and even then, because you're community-rated in small group, one bad claim can't single you out.

Where it wins

Simplicity and safety. There's no underwriting to pass, no claims risk to carry, no year-end reconciliation. For an owner who wants to write one check and not think about it, fully insured is the low-stress choice. It's also the right call if your group is small and skews older or less healthy, since community rating means the carrier can't punish you for it.

Where it hurts

You're paying for that certainty. The premium bakes in the carrier's risk margin, profit, and state premium taxes, and you never see a dime back if your people barely use the plan. In a healthy small group, fully insured is often the most expensive way to buy the same coverage — you're subsidizing the pool and handing the surplus to the insurer.

Best for: older or higher-risk groups, owners who value predictability over savings, and businesses in states where the other options are restricted.

Read the full guide: fully insured plans

Level-funded — predictable on the outside, self-insured underneath

Level-funded plans have exploded among small businesses in the last decade, and for good reason. From your seat, a level-funded plan behaves almost exactly like a fully insured one: you pay a fixed, level amount every month, and your budget is predictable. Under the hood, though, it's a different animal.

Here's the actual structure. You're technically self-insuring — paying your own employees' claims — but three things make that safe at a small scale. First, a third-party administrator runs the plan and processes claims so you're not doing it yourself. Second, stop-loss insurance caps your exposure: if claims blow past a certain point, the stop-loss carrier picks up the rest. Third, your monthly payment is set at a level that's expected to cover your claims plus those fixed costs. If your group ends up healthier than projected, a big chunk of the unused claims money can come back to you at year-end. If it's worse, stop-loss protects you, and you don't owe more than your level payment for that period.

Where it wins

For a healthy small group, this is frequently the sweet spot. You get fully-insured-style predictability and upside if your people stay well. Because a level-funded plan is a self-funded plan under federal law, it also sidesteps some state-specific benefit mandates and premium taxes, which can lower the base cost. And you get claims data — a real window into what's driving your spend, which fully insured almost never gives a small group.

Where it hurts

The screening. Level-funded carriers medically underwrite the group — they'll ask health questions or review data — and they can decline your business or quote a steep rate if your census looks high-risk. That's the opposite of guaranteed issue. So the very group that most needs the savings (an older or sicker team) is the one most likely to get turned away or priced up. It's also less of a "set it and forget it" product: you should actually read the stop-loss contract, understand your maximum exposure, and know how the year-end settlement works.

A state catch to watch

Stop-loss is regulated at the state level, and some states set minimum "attachment points" (how high claims have to go before stop-loss kicks in) specifically to keep the smallest groups from using self-insurance as an end-run around small-group rules. California sets minimums for groups under 50; New York effectively blocks the sale of stop-loss to small employers altogether, which means level-funded plans are largely unavailable there. Your state determines whether this option is even on the table.

Best for: healthy small groups that want savings and predictability, employers who want claims transparency, and companies comfortable with light underwriting — in states that permit small-group stop-loss.

Read the full guide: level-funded plans

True self-funding — usually a size too big, but know the line

Full self-funding is the model large employers use, and we cover it in depth on the 50+ page. At the very small end it's usually the wrong tool: a single premature birth or cancer case can swamp a 15-person plan, and while stop-loss exists to prevent ruin, the volatility and administrative load rarely make sense below a couple dozen stable employees.

Where it can work at the top of this range — say, a healthy, financially strong company with 30 to 49 employees and low turnover — is essentially as level-funding's more customized cousin: you take on a bit more of the claims risk in exchange for more control over plan design and, potentially, lower fixed costs. If you're near the top of the small-group band and your CFO is comfortable with cash-flow variability, it's worth modeling. For most businesses in the 2–49 range, level-funded gives you 90% of the benefit with far less exposure.

Read the full guide: self-funded plans

ICHRA — stop sponsoring a plan, start funding your people

ICHRA (Individual Coverage Health Reimbursement Arrangement) is the most genuinely new idea in employer coverage, and it inverts the whole model. Instead of picking a group plan, you give each eligible employee a tax-free monthly allowance and let them go buy their own individual health plan on the ACA market. They choose the plan and the network; you reimburse them up to the allowance you set. It came out of a 2019 federal rule and has been available since January 1, 2020.

Why owners like it

You control the cost. You decide the allowance. It's a defined contribution — a budget line you set, not a premium that renews up 15% because someone got sick. Your exposure is capped by definition.
The plan follows the employee. Because they own the policy, there's no losing coverage the day they leave, and no disruption when you change carriers — you don't have a carrier.
You can tailor by class. The rules let you split employees into legitimate classes (for example, full-time vs. part-time, salaried vs. hourly, or by geographic rating area) and offer different allowances to different classes. You can even offer a traditional group plan to one class and an ICHRA to another — you just can't offer the same class both.
It travels well. For a business with people spread across cities or states, ICHRA means everyone gets coverage that actually works where they live, instead of one group network that's great in the home office and useless three states away.

The honest downsides

Your employees have to shop. Some love the freedom; others find picking an individual plan stressful and want you to just hand them a card. Good enrollment support (which a broker provides) makes or breaks the experience.
If someone takes the allowance, they generally give up the ACA subsidy. An employee offered an affordable ICHRA can't also take a premium tax credit on the marketplace. For lower-income employees in some markets, a subsidized plan on their own might beat your allowance — the analysis matters.
It's newer, so it needs to be run right. Affordability tests, notices, substantiation of coverage — the compliance is manageable but real. (There's also a bill in Congress, the "CHOICE Arrangement," that would codify and expand ICHRA, but as of mid-2026 it's proposed, not law, so build around today's rules.)

Best for: businesses that want budget certainty, companies with a geographically scattered or high-turnover workforce, employers in high-cost group markets, and owners who'd rather fund coverage than administer a plan.

Read the full guide: ICHRA

QSEHRA — the small, simple reimbursement route

QSEHRA (Qualified Small Employer HRA) is ICHRA's older, simpler sibling, and it's aimed squarely at small businesses that don't offer a group plan. It came out of the 21st Century Cures Act in 2016. The idea is the same — reimburse employees tax-free for individual coverage and medical costs — but it's more constrained.

The key differences: QSEHRA is only for employers with fewer than 50 full-time-equivalent employees who don't offer any group health plan, and the reimbursement is capped at annual limits the IRS sets and adjusts each year (for 2026, up to $6,450 for a single employee and $13,100 for a family). There are no employee "classes" — everyone eligible generally gets the same deal — and unlike ICHRA, a QSEHRA doesn't interfere with an employee's ACA subsidy the same way (though the subsidy is reduced by the QSEHRA amount).

Best for: very small employers (think under ~15 people) who want to help with health costs, keep it simple, and stay well under the IRS caps — especially if they'd otherwise offer nothing.

Read the full guide: QSEHRA

The PEO and association routes, briefly

Two more paths come up, and both deserve a clear-eyed look rather than a sales pitch.

A PEO (professional employer organization) co-employs your staff, which lets you plug into the PEO's large-group health plan and HR infrastructure. For a tiny company, that can mean access to richer plans and steadier renewals than you'd get on your own, bundled with payroll and compliance help. The trade-offs are cost (the PEO's per-employee fee), less control, and the friction of unwinding the relationship later if you outgrow it.

Association health plans let small employers band together to buy coverage as a larger group. They exist, but tread carefully: the federal rule that expanded them in 2018 was struck down in court and formally rescinded in 2024, so AHPs now operate under the older, narrower standards, and their availability and legitimacy vary a lot by state and sponsoring association. Some are solid; some have a history of underfunding and unpaid claims. If someone pitches you one, verify the underwriting and who actually bears the risk before you sign anything.

The options at a glance

OptionWho bears the claims riskMedically underwritten?Exposed to state benefit mandates?Best fit
Fully insuredThe carrierNo (guaranteed issue)YesOlder/higher-risk groups; predictability seekers
Level-fundedYou, capped by stop-lossYesLargely no (self-funded)Healthy small groups wanting savings + data
Self-funded (true)You, capped by stop-lossYesNo (ERISA)Larger, stable, financially strong small groups
ICHRANo plan — you fund individualsNoN/A (individual market)Distributed/variable workforces; budget control
QSEHRANo plan — you fund individualsNoN/AUnder-50 employers offering nothing today

How to actually choose

Skip the brochures and answer these five questions honestly.

How healthy is your group, really? If it skews older or you know there are significant conditions in the census, fully insured (or ICHRA) protects you, because level-funded underwriting may not be kind. If your team is young and healthy, level-funded or self-funding is where the savings live.
Can you absorb a bad month? Fully insured and ICHRA give you a flat, known cost. Level-funded is nearly as smooth but has some variability and a contract you must understand. True self-funding has the most swing. Match the structure to your cash flow and your stomach.
Do you even want to sponsor a plan? If administering benefits isn't how you want to spend your time, ICHRA or QSEHRA hands the plan choice to employees and turns your role into "set the budget and reimburse."
Where do your people live and work? One office in one city points toward a group plan. People scattered across regions or states points hard toward ICHRA.
What does your state allow? Before you fall in love with level-funded, confirm your state permits small-group stop-loss. Before you assume fully insured is expensive, remember that in a pure-community-rating state your older workforce may actually be cheaper there than anywhere else.

The state variations that will trip you up

To pull it together, here's where your state quietly rewrites the rules:

Group-size definition. Up to 50 in most states; up to 100 in California, New York, and Vermont. If you're in the 51–100 range in one of those states, you may still be "small group" with all its protections.
Rating rules. Adjusted community rating everywhere, but New York and Vermont ban age rating outright, and several states ban tobacco surcharges. This shifts which structure is cheapest for your age mix.
Level-funded availability. State stop-loss regulation decides whether the smallest groups can go this route. It's freely available in much of the country and effectively off-limits in New York.
Benefit mandates. State-mandated benefits apply to fully insured (and level-funded's insured components can be affected), but true self-funded plans are shielded from most of them by ERISA. In a state with lots of mandates, self-insuring changes the benefit picture.
Continuation coverage. Federal COBRA only applies at 20+ employees. Below that, whether departing employees can continue coverage depends on your state's "mini-COBRA" law — and a few states don't have one at all.

None of this is a reason to freeze. It's a reason to model the options against your actual census and your actual state before you renew on autopilot.

Get a real side-by-side for your business

The only way to know which structure wins for your company is to run your census through all of them and compare the real numbers. That's what we do. We're an independent, carrier-neutral brokerage — we don't have a quota with any insurer — so we'll model fully insured, level-funded, ICHRA, and the rest side by side and tell you which one we'd choose in your position. Send us your employee census and current renewal; the analysis is free and there's no obligation.

Disclosures

This is general educational information for employers, not legal, tax, or benefits advice. Funding rules, IRS-set limits (like QSEHRA caps), and state insurance regulations change and vary by state; confirm the current specifics for your situation with a licensed advisor before deciding. Reviewed by Matthew T. Giberti (NPN 20698856). Last updated: 2026-07.

Ready to model your options?

Send us your census and current renewal and we'll compare fully insured, level-funded, ICHRA, and the rest side by side. Free, with no obligation.

Talk to a licensed agent

Or call {{ phone }} to talk with a licensed agent.