Tuesday, April 07, 2026

CSR forgone: Long- and short-term changes in the ACA marketplace

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When considering how the most seismic changes in the ACA marketplace’s 13-year history have shaken out, it’s important to keep in mind that the market mainly serves very low-income people. Consider*:

  • 64% of all marketplace enrollees in 2026 had income in the 100-200% FPL range. In the U.S. population at large, just 15% were in that income range as of 2024.

  • 54% of all marketplace enrollment (12,487,037) in 2026 is in ten states that have refused to enact the ACA Medicaid expansion, where eligibility for marketplace subsidies begins at 100% FPL. In expansion states, Medicaid is available to all adult citizens and qualified noncitizens with income up to 138% FPL.

  • More than half of enrollment in nonexpansion states (6,543,435) is in an income bracket (100-138% of the Federal Poverty Level, or FPL) that would qualify those enrollees for Medicaid in expansion states. Those should-be-in-Medicaid enrollees account for 28% of all marketplace enrollment.

  • In 2026, 83% of silver plan enrollees nationally had income in the 100-200% FPL range, qualifying them for strong Cost Sharing Reduction (CSR) that raises the actuarial value (AV) of a silver plan to 94% (at incomes up to 150% FPL) or 87% (at income from 150-200% FPL). Nationally, the average AV obtained by silver plan enrollees was 88.6%, justifying the presumption now enforced by several states that silver plans should be priced at a roughly platinum level (90% AV), well above gold (80% AV).

With that low-income skew in mind, I’d like to examine both long-term enrollment trends and shifts in metal selection in 2026, the latter driven mainly (presumably) by expiration of the enhanced ARPA subsidies.

Trends include: