State by State: How much more will NEW YORK residents pay if the improved #ACA subsidies aren't extended?

It was in early 2021 that Congressional Democrats passed & President Biden signed the American Rescue Plan Act (ARPA), which among other things dramatically expanded & enhanced the original premium subsidy formula of the Affordable Care Act, finally bringing the financial aid sliding income scale up to the level it should have been in the first place over a decade earlier.

In addition to beefing up the subsidies along the entire 100 - 400% Federal Poverty Level (FPL) income scale, the ARPA also eliminated the much-maligned "Subsidy Cliff" at 400% FPL, wherein a household earning even $1 more than that had all premium subsidies cut off immediately, requiring middle-class families to pay full price for individual market health insurance policies.

Here's what the original ACA premium subsidy formula looked like compared to the current, enhanced subsidy formula:

Unfortunately, the ARPA's subsidy enhancements included a major caveat: They were only in place for three years, originally scheduled to terminate effective December 31, 2023 (they were retroactive to the beginning of 2021).

The good news is that this sunset date was bumped out by another two years as part of the Inflation Reduction Act (IRA) passed in 2022. The bad news is that this extension is currently scheduled to end effective December 31, 2025. Needless to say, with Trump winning reelection and Republicans about to gain a trifecta, it's highly unlikely that the IRA's enhanced subsidies are going to be be extended further.

I decided to run the numbers myself to get an idea of just how much enrollees real-world health insurance premiums are likely to increase starting in January 2026 if the upgraded ARPA/IRA subsidies expire at the end of 2025.

For this analysis, I'm using four household scenarios, at several different income levels for each:

• a 50-yr old single adult earning between $20K - $70K/year
• a 30-yr old single parent w/an 8-yr old child, earning between $20K - $90K/year
• a 40-yr old couple w/2 children age 15 & 12, earning between $40K - $130K/year
• a 64-yr old couple earning between $20K - $90K/year

I should give a shout-out to KFF's Subsidy Calculator, which made it easier for me to run these calculations than trying to do so directly via HealthCare.Gov or the state exchanges would have been.

There's several caveats involved here.

• Both the Federal Poverty Levels (FPL) and average Benchmark Silver ACA premiums are as of 2025. For 2026, the first year that the impact of the enhanced subsidies ending would actually go into effect, FPL levels will be a bit higher, and the benchmark Silver premiums will likely be higher in most states as well due to normal factors like inflation/etc.

• In addition, the Congressional Budget Office just issued a new analysis which estimates that unsubsidized premiums will increase by an additional 4.3% on average nationally in 2026 if IRA subsidies expire in 2025. This would vary by state and carrier, but I'm tacking on an extra 4.3% to all Full Price estimates below.

• Benchmark Silver premiums vary widely from state to state, Rating Area to Rating Area, county to county and potentially even from zip code to zip code in some states. Not every plan is offered throughout an entire rating area, which can impact which Silver plan is considered the Benchmark for that area.

• I'm therefore picking a single zip code for each state...based on the capital cities. Note that the capital is also the largest city in some states but not in others.

• "Single Parent" and "Nuclear Family" scenarios: In some states, children under 19 are eligible for CHIP or Children's Medicaid at a significantly higher household income level (in some states they're eligible up to 200% FPL or more). I've noted this in the right-hand column

• These analyses assume that the enrollees choose the benchmark Silver plan. In many cases they'd be better off choosing a Gold or Bronze plan (or even Platinum, although those aren't even available in most states).

OK, with all that understood, let's take a look (note: "infinite" simply means that the net monthly premium for that household would go from $0 (free) to some number higher than $0...which technically means their premium would increase "infinity percent" even if it only went from $0 to $1/month.

Instead of going alphabetically, I've decided to analyze the states from lowest to greatest net premium increases for the most dramatic case study:

With that in mind, here's what it would look like in NEW YORK:

New York has a unique situation for several reasons:

• It's one of just 3 states (Minnesota and, just this year, Oregon) which has implemented a Basic Health Plan (BHP) program under the ACA for residents earning between 138 - 200% FPL

• Unlike either MN or OR, however, New York's BHP program has actually been retooled & expanded to cover residents earning up to 250% FPL since last April.

• In addition, New York is also newly implementing their own supplemental Cost Sharing Reduction (CSR) financial assistance program for exchange enrollees earning up to 400% FPL (the federal CSR program only extends to 250% FPL, which isn't even relevant in NY due to their BHP program covering that population instead).

• Finally, New York is one of just two states (Vermont is the other one) which has no age band whatsoever. This means that every enrollee is charged the same amount for the same ACA policy regardless of their age (in most other states, 64-yr olds are charged 3x as much as 21-yr olds). As a result, instead of the "Pre-Retirees" having the most expensive potential unsubsidized premiums, it's actually the Nuclear Family which does, since they have 4 covered lives vs. just two.

In any event, in New York:

• A single 50-yr old earning $40K/yr would see his net premiums jump by 67%, while a single parent earning $60,000/year would see a 48% increase.

• The family of four earning $80,000/year would go from paying $284/month to $497/month...a 75% increase. And if they earn $130K/year (417% FPL), their premiums would more than double from $921 to $1,964...an additional $12.5K/year for the same coverage.

For what it's worth, New York currently has 150,000 residents enrolled in subsidized ACA exchange plans; another 74,000 paying full price; over 1.54 million enrolled in their BHP program; and over 2.28 million enrolled in Medicaid via ACA expansion. That's a total of over 4 MILLION residents (20% of the total NY population) enrolled in some form of ACA coverage. Here's how that breaks out by Congressional District: