Which insurers and states are already adjusting 2026 marketplace plan offerings and premiums in anticipation of the credit expiration?
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Executive summary
Insurers in multiple markets have already baked the scheduled expiration of enhanced premium tax credits into their 2026 rate filings, and several carriers are narrowing or exiting marketplace offerings in response; early filings examined by KFF and Peterson‑KFF show explicit morbidity and rate adjustments in Vermont, Oregon, Washington and the District of Columbia, while company and state notices show carrier withdrawals or rollbacks in states such as Maryland and Illinois [1] [2] [3] [4]. These actions are not uniform — some states have countermeasures (state subsidies, Basic Health Plans, or silver‑loading policies) and many filings present two scenarios — so the picture is emergent, partial, and subject to regulatory review [2] [5] [6].
1. Insurers naming the credit expiration in filings: Vermont, Oregon, Washington and DC
A focused read of early 2026 filings shows individual carriers explicitly modeling the end of enhanced premium tax credits: Blue Cross Blue Shield of Vermont warned that loss of federal benefits will shrink enrollment and worsen the risk pool (higher morbidity) if credits expire [2], Kaiser Foundation Health Plan of the Northwest’s Oregon filing adjusted morbidity assumptions expecting ARPA premium subsidies to be discontinued [2], and Wellpoint Washington applied a morbidity adjustment anticipating healthier people will lapse coverage in 2026 [2]. KFF’s review of 23 filings across Vermont, Oregon, Washington and Washington, DC concludes insurers’ assumptions add roughly an average 4 percentage points to premiums because of the expected expiration [1].
2. Carriers signaling exits or market reductions tied to federal uncertainty
Beyond rate calculations, insurers have taken operational steps: Aetna announced an exit from ACA Marketplaces after 2025, citing federal policy uncertainty among reasons for leaving markets that affect about 1 million consumers in 17 states (including Maryland) as regulators review 2026 filings [3]. In Maryland, UnitedHealthcare’s Optimum Choice projected enrollment decline and higher rates tied to subsidy expiration and other federal actions [6] [3]. State marketplace notices likewise document carrier pullbacks: Illinois reports that Health Alliance, Aetna CVS Health and Quartz will not offer marketplace plans starting January 1, 2026, and Cigna is limiting offerings in Cook County — moves that state officials attribute to rising costs and federal subsidy changes [4].
3. States adopting countermeasures or two‑scenario rate approaches
Some states are attempting to blunt the impact or force insurers to price both with‑ and without‑extended subsidies: Washington insurers applied a uniform silver‑load adjustment in filings to try to retain subsidized enrollees even if ePTCs lapse, producing a set of rates that assume expiration and another set that would apply if credits are extended [5]. Regulators in Illinois and other jurisdictions required or accepted dual filings — insurers submitted alternate rate scenarios assuming ePTC continuation versus expiration — reflecting the recognition that rates could swing dramatically depending on congressional action [6] [3].
4. How much of a premium effect insurers expect and why
Across filings and analyst syntheses, insurers cite two linked mechanics: direct loss of subsidy lowers affordability and drives some people off the exchange, and adverse selection among remaining enrollees increases average morbidity and claims costs — together pushing proposed gross rate hikes. The Peterson‑KFF/KFF syntheses estimate that, on average across early filings, expiration adds about 4 percentage points to insurer‑requested rates and contributes to median proposed rate jumps near the high teens when combined with health cost inflation [1] [6] [7]. Georgetown’s Center on Health Insurance Reforms flagged combined policy changes (including ePTC expiry) as producing “large gross premium increases” of 7–12% on average and spurring some carriers to warn they may not continue participation [3].
5. Limits of current reporting and open questions
These early filings cover a subset of states and plans and are provisional: many insurers filed dual scenarios, regulators may require adjustments, and some states (Vermont, Washington DC) have state subsidies or alternative programs that mitigate effects — meaning national generalizations are premature [2] [6]. Reporting to date identifies specific insurers and states taking steps — BCBS Vermont, Kaiser (OR), Wellpoint Washington, Optimum Choice/UHC (MD), Aetna’s exit decision, and carrier withdrawals flagged by Illinois — but a full national accounting awaits the complete set of 2026 filings and regulator orders [2] [3] [4] [1].