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| Thanks to a court order, you can still attest to an income over 100% FPL |
It’s good to see the fight over renewal or nonrenewal of the expiring enhanced ACA marketplace subsidies sitting at the center of the current political agenda.
The enhanced summaries created by the American Rescue Plan Act (ARPA) in March 2021 are plainly the main driver of a doubling of ACA marketplace enrollment from OEP 2021 to OEP 2025 (from 12 million to 24 million). The enhanced subsidies gave the ACA a credible claim to fulfilling the mission embodied in its name, offering affordable to care to all who lack access to other affordable insurance (excepting perhaps two million in the coverage gap created by red state refusal to enact the ACA Medicaid expansion).*
Renewal or nonrenewal of ARPA subsidies will determine the basic size and shape of the ACA marketplace in 2026 and who-knows-how-many years beyond. Even if the subsidies were renewed without strings today, however, other changes to the marketplace triggered by Trump’s CMS, the Republican Congress, and political uncertainty generated by their assaults on the law are likely to inhibit 2026 enrollment substantially.
To get a working sense of how some (not all) of these restrictions function, it’s important to recognize that the majority of enrollments in the ACA exchanges are executed by brokers. Brokers played an important role in the marketplace from the beginning, but their ranks swelled from 49,000 in 2019 to 83,000 in 2024 (as CMS told me by email) - spurred first by encouragement and facilitation by the first Trump administration, and then by the increasing attractiveness of offerings and ease of enrollment when the ARPA subsidy schedule kicked in. By OEP 2024, brokers accounted for almost 80% of active enrollments in the states using HealthCare.gov, which account for about three quarters of all enrollment — up from 44% in OEP 2019. Brokers execute a large share of enrollments in most state-based exchanges as well (e.g., 56% of California’s 2 million enrollments in 2025).
