ACA Enrollment Down: Understanding the Impact of Expiring Tax Credits
The Affordable Care Act (ACA) Marketplaces are experiencing a shift in enrollment as 2026 marks the first year since 2020 without enhanced premium tax credits. Initial data released by the centres for Medicare & Medicaid Services (CMS) indicates a decline in ACA sign-ups, but a complete understanding of the impact remains elusive.
What the Numbers Show
According to CMS data, ACA sign-ups for 2026 are down by over 1 million people compared to the same time last year. This represents the first decline in sign-ups since 2020. However, these figures represent plan selections, not necessarily finalized coverage. A more detailed Health Insurance Exchanges Open Enrollment Report is expected in March or April, providing a breakdown of demographics, income, and plan choices.
The expiration of enhanced tax credits is estimated to have increased premium payments by 114%, on average, for subsidized enrollees who remained in the same plan. This significant increase raises questions about how many individuals who initially selected a plan will ultimately make their premium payments.
Understanding the Data Limitations
It’s crucial to understand that plan selection data doesn’t equate to actual coverage. A plan selection simply indicates someone has chosen a plan or been automatically renewed; it doesn’t confirm they’ve paid their premium. New enrollees generally have 30 days to submit their first payment, while returning subsidized customers have a three-month grace period—until March 31, 2026—to catch up on payments before coverage is terminated.
More than four in ten people in the ACA Marketplaces were automatically renewed into their coverage in 2025, meaning they didn’t actively re-enroll. Some of these automatically renewed customers may have disenrolled or stopped making payments upon receiving their January bills.
When Will We Have a Clearer Picture?
A timeline of key data releases will provide a more comprehensive understanding of ACA enrollment trends. The first national data on ACA enrollments will likely come out in July 2026 with the Effectuated Enrollment Report. This report will show how many people actually have coverage, based on premium payments. However, even this data may not be fully accurate, as returning customers have until the end of March to make payments.
The Effectuated Enrollment: Full Year 2026 data, expected in the summer of 2027, will provide the most complete picture, accounting for all grace periods. Additional data may come from insurer earnings calls in April and May 2026, as well as insurer rate filings in the summer of 2026. The National Health Interview Survey may also offer insights in early 2027, and CMS Risk Adjustment Data is expected in July 2027.
Frequently Asked Questions
What is “effectuated” enrollment?
Effectuated enrollment refers to the number of people who have not only selected a plan but have also made their premium payments, thereby activating their coverage.
What is the significance of the grace period for premium payments?
Returning subsidized customers have a three-month grace period to make premium payments, meaning their coverage isn’t immediately terminated if a payment is missed. This grace period complicates the immediate assessment of enrollment impacts.
Where can I find more detailed data on ACA enrollment?
More detailed data will be available through reports from CMS, including the Effectuated Enrollment Report, the Open Enrollment Report, and data from the Enrollee-Level External Data Gathering Environment (EDGE), though EDGE data for 2026 won’t be available until 2028.
As the landscape of ACA enrollment evolves, will these changes impact access to affordable healthcare for individuals and families?