Which populations (by income, age, state, or Medicaid status) will lose ACA premium tax credits in 2026?
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Executive summary
If Congress does not extend the enhanced premium tax credits that expire at the end of 2025, people with incomes above 400% of the federal poverty level will lose eligibility entirely and many lower‑income enrollees will face much smaller subsidies — pushing average out‑of‑pocket premium payments up by roughly 75–114% in 2026 in available analyses [1] [2]. Certain groups — middle‑income households (including those >400% FPL), enrollees in non‑Medicaid expansion states, lawfully present immigrants under 100% FPL, and older adults in high‑cost areas — are repeatedly highlighted in reporting as most exposed to losing credits or seeing large premium jumps [3] [4] [2].
1. Who the credits currently help — and what reverts in 2026
The ARPA/IRA enhancements (2021 and later extensions) expanded subsidy amounts and raised eligibility beyond the historic 100–400% FPL band; those enhancements are scheduled to expire at the end of 2025, reverting rules to the pre‑enhancement ACA framework in 2026 unless Congress acts [5] [6]. That means subsidy eligibility generally returns to roughly 100–400% of FPL and required household contribution percentages shift upward, reducing credit amounts for many [3] [7].
2. Income groups that will lose credits or see big hikes
The clearest cut is for households above 400% FPL: many who became newly eligible under the enhancements will no longer qualify in 2026 and will face full premiums — analyses identify about 1.6 million enrollees with incomes over 400% FPL who would be affected, and others estimate millions more uninsured if changes stand [8] [9]. Lower‑ and middle‑income households who remain nominally eligible will still face higher required contributions and thus materially smaller subsidies compared with the enhanced amounts [3] [7].
3. Age and health‑risk effects: older adults and plan affordability
Older adults, especially those near retirement age, face steep increases because premiums rise with age and subsidy formulas matter more for older enrollees; briefs show examples where a 60‑year‑old couple at ~402% FPL could see annual premiums jump dramatically — from about 8.5% of income under enhancements to nearly a quarter of income without them [10] [11]. Insurers expect some healthier people to drop coverage when credits shrink, which would push premiums higher for remaining enrollees [1] [12].
4. State differences and Medicaid expansion gaps
State variation matters. People in non‑Medicaid‑expansion states who are under 100% FPL already face limited options; some lawfully present immigrants below 100% FPL who currently receive subsidies will become ineligible in 2026 under new rules noted by KFF, deepening coverage gaps in certain states [4]. Several sources also flag that insurers’ proposed rate increases — a median ~18% in filings — interact with subsidy changes to produce larger out‑of‑pocket effects in higher‑cost states [1] [11].
5. Medicaid status, immigrants, and special eligibility rules
Lawfully present immigrants who are ineligible for Medicaid due to their immigration status and have incomes below 100% FPL will no longer be eligible for subsidized Marketplace coverage starting in 2026 — a specific population singled out by KFF [4]. In contrast, people who qualify for Medicaid are not the target of premium tax credits, so shifts mainly affect those between Medicaid eligibility and subsidy limits or those who lost expanded eligibility [13] [14].
6. Scale and estimated coverage impacts
Different analyses vary but converge on large effects: KFF and others estimate average out‑of‑pocket premium increases in 2026 of roughly 75–114% if enhancements sunset [1] [2]. Urban Institute and CBO projections cited in reporting estimate millions more uninsured and substantial strains on uncompensated care and household budgets if the credits expire [9] [15].
7. Practical implications and policy choices
If Congress extends the enhancements, the largest benefits would go to households under roughly $80,000 and most benefits to those under $200,000, per Joint Committee and CBPP summaries — a political fault line reflected in the debate over reopening government and budget negotiations [15] [5]. If not extended, some federal measures (hardship exemptions, HSA changes, state supplemental subsidies) may blunt impacts in places or for certain plan types — but these are limited and uneven across states [16] [8].
Limitations: available sources document projected and modeled impacts and show state‑by‑state variation, insurer filings, and different scenario assumptions; exact individual outcomes depend on location, age, household size, and final congressional or administrative actions not yet captured in all briefings [1] [3]. Available sources do not mention long‑term legislative developments after the cited reports.