2026 OEP Report

Final 2026 Open Enrollment Report: Household Income (100 - 200% FPL)

Turning to the 100 - 200% FPL range, 64% of all exchange enrollees fall into this income range (up slightly from 63% last year).

That's ~14.8 million people total, with ~10.7 million earning 100 - 150% FPL and the remaining ~4.1 million earning 150 - 200% FPL.

The vast majority of those in the first bracket (and most of those in the second) should be enrolled in Silver plans since they're eligible for generous CSR assistance which boosts Silver plans up to "Secret Platinum" status: If they earn up to 150% FPL Silver plans have a 94% Actuarial Value; if they earn 150 - 200% FPL Silver is boosted to 87% AV.

In layman's terms, High CSR Silver plans have either free or extremely low premiums along with extremely low deductibles & co-pays.

Unfortunately, only 9.85 million enrollees chose Silver this year...and even then, not all of them are in the 100 - 200% FPL range, which means there's quite a few who left hundreds or thousands of dollars in financial assistance for out of pocket costs on the table...except that with the enhanced federal tax credits having expired, many of these folks may have had no choice due to the increase in their premiums.

Put another way, getting a Ferrari for the price of an Audi doesn't do you much good if all you can afford is a Sentra.

In the 100 - 150% FPL range, nearly 200,000 people lost coverage...and considering that just yesterday I noted that enrollment in the 100 - 138% FPL range increased by ~325,000 people, that means enrollment from 138 - 150% FPL dropped by a stunning 522,000 enrollees!

I don't know how many of these folks actually dropped coverage vs. how many of them saw their incomes drop below the 138% threshold, although breaking it out between Medicaid expansion & non-expansion states should lend some insight:

  • In NON-expansion states, enrollment from 100 - 138% increased by ~342,000 while enrollment from 138 - 150% dropped by ~316,000.
  • In EXPANSION states, enrollment from 100 - 138% dropped by ~16,000 while enrollment from 138 - 150% dropped by ~207,000.

This suggests to me that a big part of what happened here is that several hundred thousand people saw their incomes drop below 138% FPL: In expansion states, they shifted over to Medicaid (thus disappearing from the ACA exchange tally entirely) while in non-expansion states they remained enrolled in ACA plans, just in the 100 - 138% bracket.

Enrollment from the 150 - 200% FPL range also dropped by over 218,000 people, or around 5.1% nationally.

Combined, enrollment in the 100 - 200% FPL range dropped by over 415,000 people, or 2.7% nationally, although there are 16 states where it actually increased, and 5 states (all blue, all operating their own exchanges) where it increased by double digits:

  • New Jersey: +12.4%
  • Massachusetts: +15.2%
  • Maryland: +19.3%
  • Connecticut: +29.3%
  • New Mexico: +31.4%

On the other hand, setting aside Minnesota & DC (which had nominal enrollment below 200% to begin with due to their BHP programs) and Oregon (which is a special case as they appear to still be in the process of phasing in their BHP program even though it's been in effect since July 2024), there's also several states which saw 100 - 200% FPL enrollment drop by 20% or higher, including North Carolina, West Virginia, Ohio and Vermont.

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