What will be the projected premium change for 2026 if enhanced subsidies expire?
Executive summary
If the enhanced Premium Tax Credit (PTC) subsidies expire at the end of 2025, multiple analyses and insurer filings project large premium increases for 2026: the national median proposed premium increase is about 18% in insurer filings reported by Commonwealth Fund (and insurers report double‑digit jumps) and some places show far larger local spikes (Washington’s exchange approved an average 21% increase; national gross premiums projected to rise roughly 26% by CBO per UnitedHealthcare summary) [1] [2] [3]. Independent analyses and state notices warn many enrollees will face higher out‑of‑pocket monthly bills, enrollment declines, and concentrated harm for people over 60 and those just above subsidy cutoffs [4] [5] [2].
1. What the headline numbers mean: insurers’ filings versus after‑credit costs
Insurer rate filings and state exchange decisions are predicting big year‑over‑year increases in gross premiums for 2026: Commonwealth Fund summarizes filings showing a median proposed premium increase of 18% nationally for 2026 [1]. Washington’s regulator approved an average 21% rate increase after reviewing insurer requests [2]. UnitedHealthcare notes gross premiums are projected to rise nearly 26% according to CBO‑linked figures [3]. Those gross numbers translate differently for consumers depending on whether tax credits remain: CMS projects that for eligible Healthcare.gov enrollees tax credits would still cover about 91% of the lowest‑cost plan in 2026 — leaving an average after‑credit premium of roughly $50/month — but that projection assumes continued availability of credits as modeled by CMS, not the expiration scenario insurers are pricing into their filings [6] [7].
2. Which consumers would see the biggest jump if enhancements lapse
Analysts and reporting identify several groups that would be hit hardest if enhancements end: older adults and people with incomes just above subsidy cutoffs face outsized increases. KFF and Reuters reporting cited a KFF analysis finding enrollees over 60 with incomes just above 400% of the federal poverty level face average premiums at least four times higher in some places [5]. The Center on Budget and Policy Priorities highlights that losing enhanced credits would reduce marketplace enrollment and reverse gains in coverage, with millions likely to become uninsured [4].
3. Enrollment and risk‑pool feedback: why premiums rise further than simple math
Insurers tell regulators they expect anti‑selection if credits lapse: healthier people will drop coverage, leaving a sicker, more expensive pool and putting upward pressure on rates beyond the direct subsidy cut [1] [2]. CBPP and CMS also anticipate enrollment declines and changes to plan availability as insurers adjust to a smaller, higher‑cost enrollee base [4] [7]. UnitedHealthcare and state exchanges note that some 2026 plan prices already reflect the assumption that enhancements will expire [3] [8].
4. Government and exchange responses: mitigation and mixed messages
CMS is preparing administrative steps — for example expanding hardship exemptions and catastrophic plan access — aimed at easing some consumer impacts from anticipated premium increases [7]. At the same time, CMS’s own fact sheet projects robust tax‑credit coverage under scenarios modeled for Healthcare.gov enrollees, which can appear at odds with insurers’ filed rates that assume credits lapse [6] [7]. Covered California and UnitedHealthcare explicitly warn that their posted 2026 pricing reflects expiration of enhanced credits unless Congress acts [8] [3].
5. Local variation and what to watch in your state
Rate changes are uneven: Washington approved a 21% average hike, small‑group filings show a median 11% proposed increase across small group insurers, and federal employee plans project a 12.3% average enrollee share increase [2] [9] [10]. Health exchanges and insurers advise consumers to check local marketplace sites because plan‑by‑plan and county‑level movement can diverge sharply [8] [3].
6. Limits of the available reporting and competing perspectives
Available sources disagree on magnitude because they use different baselines and assumptions: CMS’s after‑credit projections (average $50/month for the lowest‑cost plan in 2026) rest on modeling of tax credits that may not reflect a lapse scenario; insurers’ filings and state regulator approvals reflect insurer expectations if enhancements expire [6] [1] [2]. CBPP and Reuters emphasize widespread coverage losses and steep consumer pain if the PTCs lapse, while CMS emphasizes targeted administrative relief and continued access under its modeled scenarios [4] [6] [7]. Sources do not provide a single definitive, nationwide “projected premium change if enhancements expire” number; instead they provide multiple measures — median proposed premium increases (≈18%), state approvals (≈21% in Washington), and gross premium projections (≈26% per cited CBO figure) — that point to substantial consumer cost increases [1] [2] [3].
If you want, I can map those national ranges to likely out‑of‑pocket monthly impacts for specific ages and income levels in your state using the exchange and KFF methods cited here. Sources used: Commonwealth Fund (insurer filings) [1]; CMS fact sheets and guidance [6] [7]; CBPP analysis [4]; UnitedHealthcare summary noting CBO/Gross premium projections [3]; Washington Insurance Commissioner approval [2]; Reuters/KFF reporting on distributional effects [5]; Covered California notices [8]; Peterson‑KFF Health System Tracker on small group filings [9]; FEHB/OPM reporting [10].