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What role did the COVID-19 special enrollment period play in ACA enrollment numbers?
Executive summary
The COVID-era special enrollment rules — most importantly the enhanced premium tax credits and year‑round “low‑income” special enrollment opportunities introduced during the pandemic — helped drive marketplace enrollment from about 11 million in 2014 to roughly 24 million by 2025, with enrollment growth “mainly” attributed to the expanded subsidies and pandemic-era policy changes [1] [2]. Recent federal rule changes and scheduled expirations (notably the enhanced subsidies ending Dec. 31, 2025 and a pause to low‑income SEPs beginning Aug. 25, 2025) are reversing elements of that pandemic-era policy package and are central to current enrollment and cost projections [1] [3] [4].
1. Pandemic policy — the engine behind recent enrollment gains
When Congress enacted enhanced premium tax credits in the American Rescue Plan (and later extended them via other legislation), those subsidies substantially reduced net premiums for many enrollees; analysts link much of the jump in marketplace enrollment — from about 11 million earlier in the decade to roughly 24 million in 2025 — to those enhanced credits and related pandemic policies [1] [2]. The CRFB analysis reports enrollment rose to an estimated 23 million in 2025 and ties increased generosity of subsidies directly to that growth [1]. AARP likewise says marketplace enrollment “more than doubled” after the introduction of enhanced credits [2].
2. Special enrollment periods: broader access, more enrollment, and insurer worries
Beyond subsidies, pandemic-era flexibility expanded when people could enroll: policies allowed some lower‑income consumers to enroll year‑round through a “low‑income special enrollment period” so long as they met income thresholds, which made it easier for people to sign up outside traditional open enrollment windows [3]. Insurers warned that allowing year‑round enrollment for low‑income consumers could create adverse selection — people waiting until sick or needing care to enroll or switch plans — a concern reflected in later regulatory rollbacks [3].
3. Policy reversals — pause of low‑income SEP and subsidy cliff risk
Federal changes finalized in 2025 paused the low‑income SEP nationwide beginning Aug. 25, 2025 and will require additional verification for SEPs starting in 2026; HealthInsurance.org summarizes that pause and the tightening of SEP rules [4]. Simultaneously, the enhanced premium tax credits that helped drive enrollment are scheduled to expire Dec. 31, 2025 unless Congress acts — a prospect that many stakeholders say will raise premiums sharply and could reverse some enrollment gains if not extended [1] [5].
4. Numbers matter: how many depend on the pandemic policies?
Analysts put the 2025 marketplace population at roughly 23–24 million, with about 21.8–22 million of those receiving subsidized coverage — meaning the enhanced credits are directly material to most enrollees’ costs [1] [5] [6]. A KFF‑cited figure in reporting shows about 22 million of 24 million enrollees were receiving enhanced credits, highlighting how central those subsidies were to marketplace participation [7].
5. Political stakes and timing distort choices for buyers and policymakers
The impending expiration of enhanced credits has been entangled in broader budget and shutdown fights; press coverage and state marketplace officials warned that if Congress doesn’t act before open enrollment starts, consumers will “log on and see these higher premiums” and marketplaces may have limited realistic options to change the subsidy framework on short notice [3] [8]. Axios reported marketplace and state officials saying calendar timing makes substantive changes difficult just before enrollment opens [8].
6. Competing views and implicit agendas
Advocates and analysts attribute most enrollment gains to pandemic‑era subsidies and expanded SEPs [1] [2]. Insurers and some state market managers framed expanded year‑round SEPs as creating adverse selection problems that justify tightening SEP rules [3]. Policymakers pushing to end or modify enhanced subsidies cite fiscal concerns and urge negotiation; proponents emphasize coverage gains and cost relief for enrollees. Each side’s framing aligns with their institutional priorities: payers highlighting risk and fiscal actors stressing costs, while consumer‑oriented groups emphasize access and affordability [3] [1] [8].
7. What to watch next
Watch three things: whether Congress extends or reshapes the enhanced premium tax credits before Dec. 31, 2025 (because extension materially affects millions of enrollees’ premiums) [1] [7]; how the SEP verification and pause play out in 2026 enrollment data [4]; and insurer behavior — plan exits or rate changes that could reflect both higher underlying costs and changes in enrollee composition [6] [3].
Limitations: available sources in this packet document the link between pandemic-era subsidies/SEPs and enrollment growth, the pause to the low‑income SEP, and the scheduled subsidy expiration, but they do not provide a causal breakdown quantifying exactly how much of enrollment growth is due solely to the SEP rules versus subsidies versus other factors; that granular attribution is “not found in current reporting” included here [1] [3] [4].