ACA Enrollment Down: Understanding Impact of Expiring Tax Credits
- Enrollment in the Affordable Care Act (ACA) Marketplaces has dipped for 2026, marking the first decline since 2020.
- New data released by the Centers for Medicare & Medicaid Services (CMS) shows approximately 23 million Americans have signed up for ACA coverage, a decrease from the 24.2...
- Simply selecting a plan doesn’t equate to having active health insurance coverage.
Enrollment in the Affordable Care Act (ACA) Marketplaces has dipped for , marking the first decline since . This decrease coincides with the expiration of enhanced premium tax credits, which had been in place to lower healthcare costs for many enrollees. While over a million fewer people have signed up for coverage compared to this time last year, a complete understanding of the impact remains elusive and a clearer picture will not emerge for several months.
New data released by the Centers for Medicare & Medicaid Services (CMS) shows approximately 23 million Americans have signed up for ACA coverage, a decrease from the 24.2 million enrolled as of . This initial drop in enrollment doesn’t fully reflect the consequences of the expired tax credits, as it only accounts for plan selections, not actual coverage.
What are the limitations of plan selection data?
Simply selecting a plan doesn’t equate to having active health insurance coverage. Individuals are generally required to make an initial premium payment within 30 days to “effectuate” their coverage. However, returning customers who receive subsidies have a three-month grace period to make their payments. In other words that someone who selected a plan in could potentially maintain that selection in preliminary data even if they haven’t yet paid, or ultimately decide not to pay, their premium.
The expiration of enhanced premium tax credits has led to a significant increase in costs for many. On average, premiums have risen by an estimated 114% for subsidized enrollees who remain in the same plan. This substantial increase raises questions about whether individuals who initially selected a plan during open enrollment will ultimately be able to afford it.
Approximately 20 million of the current plan selections are from returning customers. A significant portion of these customers – over four in ten in – were automatically renewed into their existing plans, meaning they didn’t actively re-enroll. Some of these automatically renewed individuals may have been surprised by the higher premiums and subsequently disenrolled or stopped making payments.
When will we know more about ACA enrollment?
A timeline of key data releases will provide a more comprehensive understanding of the impact of the expiring tax credits:
- July 2026: The Effectuated Enrollment: Early Snapshot report will offer a better indication of actual coverage, as it will reflect premium payments as of . However, even this data may overestimate enrollment due to the three-month grace period for returning customers.
- Summer 2027: The Effectuated Enrollment: Full Year report will provide the most complete picture, accounting for all grace periods and potential coverage terminations.
The Effectuated Enrollment: Early Snapshot data, while helpful, may not fully capture the impact of the tax credit expiration. Individuals could drop coverage mid-year if they find premiums unaffordable, even after making an initial payment.
Additional data points will emerge from various sources throughout and .
Quarterly Earnings Reports: April and May 2026
Insurance companies like Centene and Oscar will discuss enrollment trends during their quarterly earnings calls, offering early insights into membership numbers. However, these figures may not be fully adjusted for retroactive terminations due to the grace period.
Insurer Rate Filings: Summer 2026
Insurers publicly file proposed premium rate changes with state regulators each spring and summer. These filings can provide insight into enrollment trends and the factors driving healthcare costs.
National Health Interview Survey Quarterly Releases: Likely January 2027
The National Health Interview Survey (NHIS) will provide early indications of changes in the uninsured rate. Data for the first half of is expected to become available in early .
Risk Adjustment Data: July 2027
CMS will release Risk Adjustment Program State-Specific Data, providing a state-by-state look at enrollment in ACA-compliant plans, including both on- and off-Marketplace coverage.
Issuer Level Enrollment Data: July 2027
Issuer-level enrollment data will be released, offering details on average monthly effectuated enrollment and enrollment duration.
Enrollee-Level External Data Gathering Environment (EDGE): 2028
Data from the Enrollee-Level External Data Gathering Environment (EDGE) will allow for analysis of enrollment by metal tier, but this data will not be available until and has limitations regarding enrollee demographics and coverage terminations.
The coming months will be crucial in determining the long-term impact of the enhanced tax credit expiration on ACA enrollment. While the initial data suggests a decline, a complete assessment requires waiting for more comprehensive data on effectuated enrollment and a deeper understanding of how individuals respond to the increased costs of coverage.