Have state-based marketplaces or Medicaid expansion changes in 2026 altered eligibility or PTC amounts?

1. The headline: average PTC generosity falls in 2026 because enhanced credits expired

Congressional and agency analyses make clear that the temporary expansion of PTCs that increased subsidies and capped premium contributions through 2025 is not in force for 2026 under current statutory parameters, meaning average purchaser contributions and marketplace premiums will rise and many households will see smaller or no PTCs compared with 2025 projections ^[1]. Analysts warn that, absent new legislation, that change could sharply increase premiums paid by enrollees and make coverage unaffordable for millions ^{[5] [1]}.

2. Administrative tweaks: small-dollar reductions and tougher verification on federally run exchanges

CMS has adopted operational changes for plan year 2026 that include requiring a $5 monthly payment by auto‑reenrolled zero‑premium enrollees until they confirm eligibility—effectively lowering advance PTC amounts for fully subsidized enrollees by about $5 per month on the federally‑facilitated exchange—and proposed rules that would require marketplaces to verify a large share of special-enrollment enrollments, steps CMS projects could reduce enrollment and PTC dollars in 2026 ^{[2] [4]}.

3. State-based marketplaces: new scheduling freedom but new burdens that can affect access

SBMs can set their own open enrollment periods within federal limits—starting by Nov. 1 and ending no later than Dec. 31 up to nine weeks—which gives states leeway to shape enrollment timing but may raise implementation costs and operational burdens that could influence outreach and enrollment effectiveness ^[2]. SBMs also have until 2026 to meet enhanced verification expectations or seek CMS alternatives, a compliance burden that could delay enrollments or raise administrative denials if not well-resourced ^[4].

4. Immigration-linked eligibility changes narrow who gets PTCs

Beginning in plan year 2026, lawfully present immigrants with incomes below 100% of the federal poverty level who are ineligible for Medicaid because of immigration status will not qualify for PTCs, and DACA recipients lost marketplace eligibility as of August 25, 2025, meaning a clear rule‑driven shrinkage of subsidy eligibility for some immigrant groups ^{[3] [5]}. Observers note that people who used low‑income special enrollment periods before August 25, 2025, were grandfathered, but new applicants face the stricter rules ^[3].

5. Medicaid expansion dynamics: fewer federal carrots, more state variability, and indirect effects on PTC eligibility

The extra federal incentive that temporarily boosted the matching rate for newly expanding states ended in 2026, so states choosing to expand now receive the regular 90% match but not the ARP bump—an incentive change that could slow future expansions and therefore preserve or widen “coverage gaps” in non‑expansion states where people under the poverty line remain ineligible for both Medicaid and marketplace PTCs ^{[6] [7] [8]}. Where states do not expand, low‑income adults can remain ineligible for both Medicaid and marketplace subsidies, a structural driver of uninsured risk noted by federal guidance and advocacy trackers ^{[9] [10]}.

6. What to expect in practice and where uncertainty remains

Modeling and agency estimates—cited across the reporting—anticipate millions could lose subsidies or coverage and that households just above or below key FPL thresholds will be most sensitive to the changed PTC landscape, but final enrollment and subsidy outcomes depend on state SBM implementation choices, whether Congress restores enhanced PTCs, and how verification and auto‑reenrollment policies are applied in practice; the sources do not resolve those future political or administrative moves ^{[1] [4] [5]}.