How will expiration of expanded premium tax credits after 2025 affect marketplace premiums and enrollment?
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Executive summary
If Congress allows the enhanced premium tax credits (ePTCs) that were enacted under ARPA and extended through 2025 to expire, multiple analyses project sharply higher out‑of‑pocket marketplace premiums (KFF estimates average premium payments would rise 114% from $888 in 2025 to $1,904 in 2026) and large drops in enrollment (CBO projects marketplace enrollment falling from 22.8 million in 2025 to 18.9 million in 2026; Urban Institute and others estimate between about 4 million and 7.3 million people would lose coverage, with 4.8 million becoming uninsured in some estimates) [1] [2] [3] [4]. Congress has not ended the PTC program itself, only the temporary enhancements—the baseline credit continues absent legislative change [5].
1. What is actually expiring — not the tax credit itself but the temporary enhancements
The statutory premium tax credit remains part of the ACA; what expires at the end of 2025 is the temporary ARPA/IRA expansion that (a) capped out‑of‑pocket benchmark plan premiums at lower shares of income for enrollees and (b) extended eligibility above 400% of the federal poverty level. The Library of Congress’s CRS makes this distinction explicit: the PTC continues but the temporary expansion that increased subsidy amounts and eligibility runs only through 2025 unless Congress acts [5].
2. Short‑term marketplace premium effects: big increases for subsidized enrollees
Multiple policy analysts model a large jump in what consumers pay if the ePTCs lapse. KFF’s estimates show average annual premium payments for subsidized enrollees would more than double—an increase of 114%, from $888 in 2025 to $1,904 in 2026—reflecting both higher required contributions and projected premium growth [1] [6]. The Center on Budget and Policy Priorities and Peterson‑KFF have similar warnings that many enrollees will face sharply higher monthly bills [7] [8].
3. Insurer pricing and “gross” premiums — modest additional upward pressure
Insurers say expiration will push gross premiums somewhat higher because the remaining enrollee pool would be sicker on average. Early filings and insurer statements show examples: Vermont carriers expect gross premiums in 2026 to be about 6–7% higher than they otherwise would be because healthier enrollees would be more likely to leave the market if subsidies shrink [9]. Analysts caution that gross premium responses vary by market and insurer.
4. Enrollment and coverage losses: substantial but range across estimates
Estimates of coverage loss differ by methodology and year. The CBO estimated marketplace enrollment falling from 22.8 million in 2025 to 18.9 million in 2026 if the ePTCs expire [2]. The Urban Institute and organizations that use its work project larger disruptions: briefs cite scenarios with roughly 4–7.3 million people losing marketplace coverage and 4.8 million becoming uninsured in 2026 in some analyses [3] [10] [4]. The Commonwealth Fund, AHA, and other researchers emphasize disproportionate impacts in states that did not expand Medicaid and in rural areas [10] [11].
5. Federal and provider budget impacts: higher uncompensated care and fiscal tradeoffs
Analysts project fiscal and system effects beyond premiums. The Robert Wood Johnson Foundation summarizes Urban Institute work estimating more uncompensated care and lost provider revenue — for example, $7.7 billion more uncompensated care and over $32 billion in lost provider revenue in 2026 under some scenarios — while CBO has estimated costs to restore expanded credits if Congress reverses course [3] [4].
6. Who bears the brunt — middle incomes, non‑Medicaid states, and vulnerable communities
When the ePTCs are removed, middle‑income consumers above the 400% FPL threshold are pushed off subsidies and many lower‑income households face larger cost‑sharing relative to income. Analysts and state exchanges note that people in non‑Medicaid expansion states, rural communities, people of color, part‑time and gig workers, and small‑business owners would be especially affected [7] [10] [11].
7. Uncertainties and differing assumptions in the forecasts
Projections differ because models use different baseline enrollments, assumptions about 2026 premium growth, behavioral responses (how many people drop coverage), and state‑level policy responses. KFF’s numbers apply an 18% assumed rise in average premiums for 2026 when modeling the “no ePTC” scenario; Vermont insurers base their estimates on local risk mix and filings; CBO, Urban Institute and others use alternative micro‑simulation approaches, producing ranges rather than a single definitive outcome [6] [9] [2].
8. What remains unclear in reporting
Available sources do not mention specific, finalized national insurer rate filings that incorporate the full behavioral exit assumed in the largest coverage‑loss estimates, nor do they show a single consensus estimate for 2026 across all models; instead, there is a cluster of projections with consistent direction—higher premiums and lower enrollment—but quantitative range varies by source [1] [2] [3].
Bottom line: letting the enhanced subsidies expire will not end the PTC but will sharply raise what many marketplace enrollees pay, put meaningful upward pressure on gross premiums in some markets, and—by most credible models—cause millions to lose marketplace coverage or become uninsured, with outsized effects in states that didn’t expand Medicaid [5] [1] [2] [10].