CMS's latest snapshot of private plan enrollment in ACA marketplaces shows significant attrition, from 10,197,187 total enrollments as of March 31 to 9,949,079 as of June 30, a drop of 2.4%. That's mainly -- in fact entirely -- because of stepped-up enforcement of citizenship or immigration status.
That increased vigilance also explains an apparent anomaly that jumped out at me from the numbers: the drop in plan holders whose plans are enhanced with Cost Sharing Reduction (CSR) subsidies is larger than the drop in enrollment among silver plan holders. Since CSR is available only with silver plans, one might have assumed that a drop in CSR enrollment would simply reflect a drop in silver plan enrollment among those with incomes under 250% FPL, the cutoff for CSR eligibility. Yet CSR enrollment dropped by 278,103 -- 4.8% -- compared to a silver enrollment drop of 142,336 (2.0%).
It turns out that the marketplaces are cracking down on enrollees whose stated income doesn't match other data, presumably mainly from tax returns, and reducing or withdrawing CSR benefits as well as premium subsidies when enrollees don't verify their income claims. That's in tandem with increased enforcement with respect to immigration or citizenship status. Here's the explanation:
