Last year, we covered major changes to the Affordable Care Act (ACA) included in the “One Big Beautiful Bill” in our blog, What Individuals and Businesses Should Know About the 2026 ACA Changes. One of the most closely watched updates was the expiration of the enhanced premium tax credits, a shift that many health policy experts and even the Congressional Budget Office warned could trigger a mass exodus from the ACA marketplace.
Heading into Open Enrollment, headlines amplified those concerns. Throughout November and December, media coverage highlighted the sticker shock some enrollees experienced as subsidies reverted to pre-enhancement levels, raising questions about how many individuals would drop coverage altogether.
But now that enrollment data has been released, the story is more nuanced than early predictions suggested. Yes, enrollments declined — but not off a cliff. As is often the case in healthcare policy, the reality sits somewhere between projections and panic. Let’s take a closer look at what actually happened in the marketplace.
The Final Enrollment Numbers
According to data released by CMS on January 28th, just under 23 million people enrolled in ACA plans through Marketplace and state-based exchanges. That represents a decrease of ~1.2 million people, or -5%, compared to 2025 enrollments. There were 22,973,219 total enrollments, of which ~3.4 million were new enrollments and ~19.6 million were people who already had coverage who re-enrolled. Nine states plus Washington D.C. saw an increase in the number of enrollments. The rest of the states saw a decline in enrollments.
Which States Fared Best and Worst?
According to data from the 2025 and 2026 CMS reports, the states that saw the biggest increase in percentage of people enrolled compared to 2025 were:
| State | 2025 Enrollments | 2025 Enrollments | Difference | % Change |
| New Mexico | 70,371 | 80,163 | +9,792 | 13.90% |
| Texas | 3,966,226 | 4,172,233 | +206,007 | 5.20% |
| Massachusetts | 368,382 | 385,361 | +16,979 | 4.60% |
| Idaho | 117,373 | 120,426 | +3,053 | 2.60% |
| Connecticut | 147,072 | 150,719 | +3,647 | 2.50% |
| District of Columbia | 14,058 | 15,323 | +1,265 | 9.00% |
| New Jersey | 484,540 | 493,816 | +9,276 | 1.90% |
| Louisiana | 292,994 | 296,648 | +3,654 | 1.30% |
| Maryland | 247,243 | 248,770 | +1,527 | 0.60% |
| California | 1,902,566 | 1,910,476 | +7,910 | 0.40% |
It’s worth noting here that states in the list that saw the biggest gains cushioned the blow by stepping in at the state-level to mitigate the effects of the expiring federal tax credits. New Mexico offered a full reimbursement of the lost subsidies. Six other states offered some form of relief based on household income.
The states that saw the biggest decline in percentage of people enrolled compared to 2025 were:
| State | 2025 Enrollments | 2025 Enrollments | Difference | % Change |
| North Carolina | 975,110 | 761,457 | −213,653 | −21.9% |
| Ohio | 583,443 | 469,616 | −113,827 | −19.5% |
| West Virginia | 67,113 | 55,879 | −11,234 | −16.7% |
| Indiana | 359,240 | 300,049 | −59,191 | −16.5% |
| Arizona | 423,025 | 357,144 | −65,881 | −15.6% |
| Delaware | 52,931 | 44,663 | −8,268 | −15.6% |
| Oregon | 139,688 | 118,372 | −21,316 | −15.3% |
| Oklahoma | 307,989 | 261,887 | −46,102 | −15.0% |
| Georgia | 1,519,153 | 1,301,254 | −217,899 | −14.3% |
| Rhode Island | 43,514 | 38,071 | −5,443 | −12.5% |
Key Takeaways
Last year, the Congressional Budget Office projected that as many as 2.2 million people could lose or drop ACA health insurance coverage just in 2026. Other think tanks predicted losses in the 4 million range. So, were those predictions off-base?
The short answer is: it’s too early to say. Open enrollment in some states ran through January 31, and early federal reports only captured data through mid-January. Additionally, KFF reports that enrollees counted in preliminary data may drop off for other reasons throughout the year, such as canceling their coverage by choice or non-payment of premiums. That takes a few months to shake out. The real numbers will likely become clearer in summertime, when new data showing effectuated enrollment is released; that is, those who actually kept their plans and paid for them.
There are also reasons enrollment didn’t immediately collapse. For many consumers, the individual market is the only coverage option available. Rather than going uninsured, some likely downgraded to lower-cost plans. Others may be holding out hope that Congress revisits subsidy extensions. Legislation has already passed the House but remains stalled in the Senate.
The biggest takeaway here is that the preliminary data doesn’t tell the whole story. It will take time to understand the true impact of the expired tax credits and ACA enrollments.
What it Means for ICHRA
For ICHRA, the individual market proved more resilient than expected — and that’s a good thing.
ICHRA relies on a functioning individual marketplace. At the same time, ICHRA contributes to stability of the individual market by bringing employer-funded, generally healthier working populations to the risk pool. If the market had seen dramatic contraction, employer confidence in ICHRA could have been shaken. Instead, the market held up even without short-term subsidy boosts.
This resilience reinforces what we’ve long believed: ICHRA is not a temporary workaround, it’s a durable, long-term benefits strategy.
Learn more about ICHRA with Benafica, and our ICHRA platform BEN360.