How do ARP subsidies compare to pre-2021 ACA subsidy levels?
Executive summary
The American Rescue Plan (ARP) and the Inflation Reduction Act (IRA) increased and temporarily expanded ACA premium tax credits from 2021 through 2025: they lowered required enrollee contributions (for many making premiums effectively free at low incomes), removed the 400% FPL eligibility cap through 2025, and produced substantially larger subsidies and lower after-subsidy premiums versus pre‑2021 rules (e.g., average household savings over $800/year and much higher share of enrollees finding very low-cost plans) [1] [2] [3].
1. How ARP/IRA changed subsidy size: bigger checks, lower required shares
Before ARP, the ACA required people to pay a specified percentage of income toward the benchmark (second‑lowest‑cost Silver) plan; ARP/IRA reduced those “applicable percentages,” so across income bands eligible enrollees pay a smaller share of income and receive larger premium tax credits [1] [4]. For example, people between 100% and 150% of FPL can effectively have the benchmark premium fully covered under the ARP/IRA enhancements — a departure from the pre‑2021 schedule where they paid a non‑zero share [3] [5].
2. Expansion of eligibility — temporary removal of the 400% cliff
A major practical difference from pre‑2021 policy is the temporary lifting of the 400% FPL cutoff: ARP extended eligibility above 400% FPL when premiums would otherwise exceed 8.5% of income, meaning some higher‑income households who had no subsidy before became eligible through 2025 [1] [6]. The 400% “subsidy cliff” that existed from 2014–2020 returned as a policy concept if enhancements expire after 2025 [7] [8].
3. Quantifying the impact — reported savings and enrollment effects
Reporting tied the enhanced credits to large reductions in premiums and enrollment growth: studies cited show large average savings (for example, a commonly cited figure is average household savings over $800/year) and dramatic increases in enrollment and low after‑subsidy plan prices — e.g., “80% of federal marketplace enrollees could find a plan for $120 or less per year” early in the ARP period and large decreases in required contributions for many households [2] [9] [3]. CMS and analysts also documented significant federal spending increases tied to the enhanced structure between 2014 and 2025 [3].
4. What “reverting to pre‑2021 rules” would mean in practice
If enhanced PTCs are not extended past 2025, the rules will revert to the statutory ACA parameters: the 400% FPL cap returns, applicable percentages increase (meaning enrollees pay a larger share of income toward the benchmark plan), and subsidies shrink for most current recipients compared with ARP/IRA levels [1] [10] [4]. Analysts and advocacy materials warn that many enrollees would face higher premiums or lose eligibility entirely, producing what’s commonly described as the return of the “subsidy cliff” in 2026 [7] [8].
5. Where sources agree and where they differ
All provided sources agree on the core facts: ARP/IRA temporarily expanded eligibility and increased subsidy amounts for 2021–2025, producing larger subsidies and enrollment effects relative to the pre‑2021 ACA baseline [1] [3] [6]. Differences across sources are emphases: advocacy and congressional materials highlight consumer savings and access gains [2]; policy analysts and CMS materials stress cost and fiscal impacts and the technical details of how required enrollee percentages would change if enhancements expire [4] [3].
6. Limits of current reporting and unanswered specifics
Available sources document the general scale and mechanics of the enhancements and describe scenario examples, but they do not provide a single uniform table comparing every exact pre‑2021 percentage versus ARP percentages for all FPL bands in one place in these snippets — readers seeking a cell‑by‑cell percentage comparison should consult the primary CMS/IRS tables or the appendix materials referenced in the Congressional Research Service note [1] [4]. Also, while sources quantify average savings and enrollment change, local variations (state, age, plan mix) mean individual impacts will differ [2] [9].
7. Bottom line for consumers and policymakers
Compared with pre‑2021 ACA subsidy levels, ARP/IRA subsidies from 2021–2025 are larger, apply to more households (including some above 400% FPL), and reduce enrollee premium contributions across the board; letting the enhancements expire would shrink subsidies and reinstate the 400% FPL limit beginning in 2026, raising costs for many marketplace enrollees [1] [7] [4]. Policymakers must weigh consumer affordability gains against federal costs when deciding whether to extend, modify, or end the temporary enhancements [3] [9].