Are cost-sharing reductions (CSRs) still available and who loses them?
Executive summary
Cost‑sharing reductions (CSRs) remain available in 2025–2026 for people who buy a Marketplace silver plan and meet income and eligibility rules: generally households with modified adjusted gross income (MAGI) between 100% and 250% of the federal poverty level (FPL) get reduced deductibles, copays and lower out‑of‑pocket limits when they enroll in a Silver plan (examples: $3,050 max OOP for many enrollees in 2025) [1] [2] [3]. CSRs apply only to Silver plans; consumers who are eligible but pick Bronze, Gold, or other non‑Silver plans do not receive the CSR benefit [1] [4].
1. What CSRs are and who currently qualifies
Cost‑sharing reductions are federal subsidies that lower out‑of‑pocket costs — deductibles, copayments, coinsurance and maximum OOP — for eligible Marketplace enrollees who buy a Silver plan. Eligibility is tied to income measured as MAGI: most sources in current reporting put the main eligibility band between 100% and 250% of FPL, with the deepest reductions for 100–200% FPL and more modest reductions for 200–250% FPL [1] [2] [5].
2. How the benefit is delivered — Silver plans only
All official guidance emphasizes that CSRs are only delivered if an eligible enrollee selects a Silver plan on HealthCare.gov or a state Marketplace. The CSR is “built into” the Silver plan design so the consumer automatically gets the lower cost‑sharing amounts; choosing a non‑Silver plan forfeits the CSR even if the person otherwise qualifies [1] [4] [6].
3. Size of the reductions and real dollar examples
Federal and independent analyses show the scale: for many people with income between 100% and 200% FPL, the modified Silver plan reduces the annual out‑of‑pocket cap to about $3,050 for a single individual in 2025, versus a much higher standard cap without CSRs [2] [3]. For those at 200–250% FPL, reductions are smaller and out‑of‑pocket caps are higher than the 100–200% band [2] [5].
4. Who loses CSRs and why
There are three distinct groups that lose CSR benefits: (a) people whose income exceeds the 250% FPL threshold — CSRs do not apply above that band [5]; (b) people who qualify by income but enroll in non‑Silver plans (Bronze, Gold, Platinum or catastrophic) — they forfeit the CSR because the benefit is tied to Silver plan designs [4] [1]; and (c) people who are ineligible for Marketplace subsidies for other reasons (e.g., not filing required tax returns or other statutory eligibility rules referenced by Marketplace guidance) — CMS materials list procedural eligibility requirements linked to premium tax credits and CSRs [7].
5. Policy friction: funding, “silver‑loading” and state choices
Recent policy debate affects how insurers and marketplaces reflect CSR costs in premiums. The practice called “silver loading” — where insurers raise Silver premiums to reflect CSR obligations (and rely on premium tax credits to subsidize those premiums) — was codified in 2026 federal guidance for states that permit it, and Congress considered (but ran into procedural hurdles on) appropriations to pay insurers directly for CSRs [8]. That matters because shifts in federal policy or state regulator decisions can change premiums and how visible CSR costs are to consumers [8].
6. Numbers at scale and practical consequences
Independent estimates indicate millions of enrollees use CSR‑enhanced Silver plans — analyses cited more than 12.5 million people in CSR‑benefit plans as of early 2025, representing a large share of Marketplace enrollees [3]. Practically, losing CSRs can mean facing much higher deductibles and copays or needing to switch to a Silver plan to reclaim the benefit; consumer guidance repeatedly stresses choosing the Silver plan to capture these savings [4] [6].
7. What current sources do not say (limits of reporting)
Available sources do not mention post‑2026 legislative changes beyond the 2026 guidance and the 2025 Congressional activity referenced; they do not provide a definitive list of every state‑level decision about silver loading or insurer contract choices for 2026 or later [8]. They also do not list exact dollar thresholds for every family size beyond sampled examples; consumers should consult their state Marketplace for the precise MAGI cutoffs that apply to their household [4] [9].
Bottom line: CSRs remain active and deliver substantial out‑of‑pocket relief for people with MAGI roughly between 100% and 250% of FPL — but only if they enroll in a Silver Marketplace plan; those who enroll in other metal levels, whose incomes exceed eligibility bands, or who fail other Marketplace eligibility steps lose the CSR benefit [1] [2] [4].