Final 2025 Open Enrollment Report: Household Income (<138% FPL)

Finally, we come to HOUSEHOLD INCOME BRACKETS.

This is, of course, extremely important since household income is one of the most critical factors in calculating how much financial assistance enrollees receive (or if they're eligible for Advance Premium Tax Credits (ATPC) at all).

Since there's so many income bracket columns and there's a lot to delve into for many of them, I've broken the full spreadsheet out into three sections/posts. The first focuses on exchange enrollees who earn less than 138% of the Federal Poverty Level (FPL). This is a critical threshold because it's the cut-off point for ACA Medicaid expansion enrollment in the 40 states (+DC) which have expanded it.

Nationally, over 31% of all exchange enrollees earn less than 138% FPL, which may sound surprising given that 41 states have expanded Medicaid...until you realize which states haven't done so yet: Over 4.5 MILLION enrollees in Florida and Texas alone earn less than 138% FPL (2.4 million & 2.1 million respectively).

Across all ten holdout states (AL, FL, GA, KS, MS, SC, TN, TX, WI & WY), over 7.6 million ACA enrollees are below the cut-off point; the vast majority of them would be shifted over to Medicaid instead if their states expanded the program.

Note that I said "the vast majority..." not all of them. As you can see, even in the expansion states there's still over a million enrollees who you'd normally expect to be enrolled in Medicaid instead but aren't, mainly because documented immigrants who haven't lived in the United States for at least five years aren't eligible for Medicaid but are eligible for ACA subsidies. In fact, this category of new residents are eligible for subsidies even if they earn less than 100% FPL, which is a bit odd since U.S. citizens aren't...as evidenced by the Medicaid Gap.

Note: Don't be surprised if this population sees their ACA subsidy eligibility messed with by the House GOP's budget proposal (I haven't done a deep dive into it yet but this is exactly ths sort of thing I could easily see them trying to drop).

Speaking of exchange enrollees under 100% FPL, there's 211,000 of them in expansion states, plus another 337,000 in non-expansion states (548,650 nationally). Besides documented immigrants who aren't eligible for Medicaid, there are other exceptions to this:

Estimated household income at least 100% of the federal poverty line. You may qualify for the PTC if your household income is less than 100% of the federal poverty line and you meet all of the following requirements:

• No one can claim you as a dependent for the year.
• You or an individual in your tax family enrolled in a qualified health plan through a Marketplace.
• The Marketplace estimated at the time of enrollment that your household income would be at least 100% of the federal poverty line for your family size for (the current year).
• APTC was paid for the coverage of one or more months during (the current year).
• You otherwise qualify as an applicable taxpayer (except for the federal poverty line percentage).

Alien lawfully present in the United States. Certain aliens with household income below 100% of the federal poverty line are not eligible for Medicaid because of their immigration status. You may qualify for the PTC if your household income is less than 100% of the federal poverty line if you meet all of the following requirements.

• No one can claim you as a dependent for the year.
• You or an individual in your tax family enrolled in a qualified health plan through a Marketplace.
• The enrolled individual is lawfully present in the United States and is not eligible for Medicaid because of immigration status.
• You otherwise qualify as an applicable taxpayer (except for the federal poverty line percentage).

You'll note that enrollees under-138% FPL only make up 9.3% of all enrollees in Medicaid expansion states...vs. over 50% of those in non-expansion states.

If all ten states were to expand Medicaid at once, ACA exchange enrollment would plummet by up to 6.2 million or so...over 25%.