So, what does this mean for monthly effectuated enrollment this year? Well, it's pretty safe to say that it's not going to look anything like the ePTC years [ie, 2021 - 2025]; in fact, at least a half-dozen state-based ACA exchanges have posted press releases warning that they're already seeing record levels of plan cancellations.
Instead, it seems pretty clear that the pattern is much more likely to resemble one of the NON-ePTC years. Here's what it would look like if effectuations in 2026 follow the exact path of those years...
...Depending on which year it mimics, average 2026 effectuations will range somewhere between 18.2 million - 20.9 million per month. If so, this would mean anywhere from 1.4 - 4.1 million fewer exchange enrollees than 2025.
Medicare Advantage (technically "Medicare Part C" & originally called "Medicare+Choice") is a type of health plan in the United States offered by private companies as part of the original Social Security Act of 1965 that created Medicare. It permits a private insurance option that wraps around traditional Medicare. Medicare Advantage plans attempt to fill some coverage gaps and offer alternative coverage options.
Under Part C, Medicare pays a plan operator a fixed payment for each enrollee. The operator then pays for their medical expenses. Traditional Medicare directly compensates providers on a fee-for-service basis. Plans are offered by integrated health delivery systems, labor unions, non profit charities, and health insurance companies, which may limit enrollment to specific groups of people (such as union members).
Long-time readers know that I've long been an advocate of more states breaking off of the federal ACA exchange (HealthCare.Gov) and establishing their own versions instead. While there are certainly benefits to utilizing the federal exchange (standardized interface, user experience, branding & marketing), there are also numerous benefits to states operating their own platforms.
In the early days of the ACA, in addition to the infamous technical meltdown of HealthCare.Gov, many of the state-based exchanges (SBEs) of the time included horror stories in which the 1.0 versions of SBEs either failed miserably, cost an insane amount and/or both. The most famous examples include...
The Illinois Health Benefits Exchange, which operates the states new ACA exchange, Get Covered Illinois, has published their June advisory committee meeting slide deck. Let's dig in!
Enacted state healthcare legislation
HB 0111: DOI Budget Appropriation: Approval of DOI’s budget appropriation request, which includes $72,345,000 in resources to support GCI’s operation and additional headcount to support the hiring of six new GCI positions.
SB 3815: Health Insurance Enrollment Protections: Prohibits insurers from denying enrollment in coverage when an individual has past-due premiums from a previous plan unless specific conditions are met. Prohibiting insurers from stacking past-due premiums on the initial binder payment and requires insurers to offer a 12-month payment plan for past-due premiums.
SB 3508: Annual DOI Administrative Cleanup Bill: Among other insurance-related items, allows GCI to adopt new federal regulations more easily to ensure timely compliance with ACA provisions.
The chart below contains proposed rates for Plan Year 2027, which will be reviewed for compliance with federal and state requirements. Please submit any comments to DOI.HealthRateReview@illinois.gov by Friday, July 10, 2026.
As I and many others have been warning about for the past year or so, the upcoming so-called "work requirements" (aka "paperwork hell" requirements) of last year's Big Ugly Bill are ramping up in January...and in fact have already begun in Nebraska. A few days ago the Centers for Medicare & Medicaid Services (CMS) published their "final rule" with the reporting and exemption regulations which every state which has expanded Medicaid under the Affordable Care Act will be required to follow...and, as expected, it's likely to be a disaster.
Advocates for people with serious illnesses, like cancer and HIV, say the strict Medicaid work rules that the Trump administration released this week are likely to put ongoing treatments in jeopardy.
