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Last week, Paige Cunningham at Notus reported* that effectuated ACA marketplace enrollment in April was down 21% from end-of-OEP plan selection totals in the 30 states using HealthCare.gov. For all states, April totals were 17% below end-of-OEP, as attrition was far lower in the 20 states that run their own marketplaces. * About half of the SBMs have somewhat mitigated the effect of the expiration of the enhanced subsidies that were funded only through 2025, offering either supplemental state subsidies, strict silver loading, or Basic Health Programs.
As Charles Gaba has highlighted, the end-of-OEP-to-April drop in 2026 was just about double the 2025 drop of 8.8%. Year-over-year, effectuated enrollment in April is down 13.5%, from 22.2 million in 2025 to 19.2 million this year.
One caveat about terminology that will be relevant going forward: Cunningham reports that 21% of end-of-OEP enrollees in the FFM were “dropped from coverage” after failing to pay their first premium. What she actually appears to have reported, though, is a net difference between total plan selections as of the end of OEP and effectuated enrollment in April. Every month, some people drop coverage and others newly obtain it via individually granted Special Enrollment Periods (SEPs), available after various types of life changes, such as losing employer-sponsored coverage. From February of 2022 to August of last year, SEPs were automatically granted to anyone who reported a qualifying income below 150% FPL. Trump’s CMS cut that automatic SEP off as of August 2025 (a change ratified in the Republican monster bill signed on July 4, 2025) - - and consequently, enrollment dropped from April to December last year for the first time since 2020. (In 2021, a pandemic-induced emergency SEP effectively kept enrollment open to all for more than half the year.)

