ACA Signups EXCLUSIVE! FINAL 2025 Open Enrollment Report published: 24.3M QHPs; 26.1M w/BHPs included!

The most recent press release from the Centers for Medicare & Medicaid Services (CMS) which included actual enrollment data about the 2025 ACA Open Enrollment Period (OEP) came out back on January 17, 2025 as one of the final communications from the outgoing Biden/Harris Administration.

This press release didn't include any accompanying Public Use Files (PUFs) since it only included semi-final enrollment data for the 2025 period.

Final top-line numbers were available for the 31 states hosted via the Federally Facilitated Marketplace (FFM), HealthCare.Gov...but the enrollment data was still preliminary for the 20 State-Based Marketplaces (SBEs), several of which hadn't even wrapped up Open Enrollment yet (including CA, DC, MA, NJ, NY, RI & VA). A few states final enrollment deadlines wouldn't hit until January 31st, over a week into the new Musk/Trump Regime.

At the time, CMS under the Biden Administration put the semi-final total enrollment nationally at around 21.16 million on-exchange Qualified Health Plans (QHPs), plus another 1.75 million Basic Health Plan (BHP) enrollees across New York, Minnesota and Oregon. The combined QHP/BHP tally was 25.92 million...with up to 3 weeks of enrollment data still missing across 11 states. (Technically a whopping 55 days of data was missing from Rhode Island, which suffered a massive data breach of their entire social services computer system last winter).

Normally, CMS publishes their final, official annual Open Enrollment Period report--along with the accompanying Public Use Files (PUFs) which contain the hard demographic data, sometime in late March, right around the ACA's anniversary (President Obama signed it into law on March 23, 2010). This year, however, that date came and went without a peep from CMS.

While the first Trump Administration did continue to publish these reports every spring, I've been skeptical as to whether they'd continue to do so this time around, given the Musk/Trump Regime's history of purging terabytes of critical healthcare data from federal government websites as well as Trump's long-established dislike of the ACA itself. And so far, my suspicions have proven accurate: As of May 11th the 2025 Marketplace Open Enrollment Period Public Use Files are still not published on the CMS website...they only run through 2024.

HOWEVER, while there's been no press release yet nor a webpage devoted to the final 2025 OEP report, it turns out the Public Use Files themselves are indeed available at the CMS website today.

With that in mind, let's dig in!

Note before I start: While it's always possible that the Musk/Trump Regime has manipulated the data (as I warned back in January), a cursory look at the top-line numbers suggests that it seems to be accurate; the statewide enrollment data for the 31 FFM states which was already finalized prior to January 20th matches, and the increase in the final top-line numbers for the states which had incomplete data seem to be in line with what I'd expect, so I'm reasonably confident that it's legit.

The table below has the data for both Qualified Health Plans (QHPs) in all 50 states + DC as well as Basic Health Plan (BHP) enrollment in Minnesota, New York & Oregon only, compared to the 2024 OEP.

I've also grouped the data by type of ACA exchange (federally facilitated or state-based) and by Medicaid expansion status. The main takeaways are pretty much the same as I've written about earlier this year, with some slight modifications as the final numbers have come in:

• Overall QHP enrollment is up 13.4% y/y (+2.87M)
• Overall BHP enrollment is up 37.7% y/y (+491K)
  (this is entirely due to New York expanding their BHP program to include enrollees earning up to 250% FPL as well as Oregon launching their BHP program mid-year)
• Federal exchange enrollment is up 13.8% y/y (+2.07M)
• State-based exchange enrollment is up 12.6% y/y (+802K) without BHPs (up 15.1% w/BHPs included)

The grand total of QHPs + BHPs combined is 26,112,408 people...which is 191,095 higher than where I had it as of the semi-final tally in January (QHPs added 153,222 & BHPs added 37,873 since then).

Since Medicaid expansion "cannibalizes" a large chunk of enrollees who'd otherwise be eligible for QHPs (similar to how BHPs do), that's another important factor:

• EXPANSION state enrollment is up 12.7% y/y
• NON-expansion state enrollment is up 14.0% y/y

Unlike the prior 2 years, there doesn't seem to be much of a difference in QHP enrollment growth between expansion & non-expansion states or between federal vs. state-based exchanges this year. Of course this is complicated by the fact that Georgia changed its status from a FFM state to an SBM state this year.

Some key state numbers:

• Highest y/y QHP enrollment increase by percentage: LOUISIANA, up a stunning 37.9%!
• 5 other states saw enrollment increase of more than 25% y/y: WV, KY, NJ, MI, MA
• Highest y/y QHP increase by sheer number: FLORIDA, up a jaw-dropping 523,000 (+12.4%)
• 5 other states saw enrollment increases of more than 100,000: TX, GA, CA, NJ & MI.

At the opposite end:

Four states saw a net drop in QHP enrollment year over year, three of which have a very obvious explanation:

• New York dropped 23.3% (over 67,000 enrollees)...because they expanded the upper income limit of their Basic Health Plan (BHP) program from 200% FPL to 250% FPL. As a result, their BHP enrollment increased by a whopping 465,000 people (nearly 7x as many as dropped QHP coverage!)
• North Carolina dropped 5.1% (~53,000 enrollees)...while at the same time continuing to ramp up their Medicaid expansion program (which broke 650,000 in April!)
• Oregon dropped 4% (~5,800 enrollees)...while simultaneously launching their own BHP program starting last July (it enrolled nearly 32,000 people during 2025 OEP).

That just leaves Virginia as the only state which lost exchange QHP enrollees this year (down 2.8%, or 11.2K people) without having an obvious reason for it.

Florida once again has by far the highest percent of its total statewide population enrolled in ACA exchange QHPs: 20.3%, or 1 out of every 5 Floridians. Part of this is due to them not expanding Medicaid, but no other non-expansion state has more than 13.5% of their populations enrolled in exchange plans.

At the opposite end is Hawaii: Just 1.7% of its total population is enrolled in an on-exchange QHP. New York technically only has 1.1%, but again that doesn't include BHP enrollees; throw them in and they're at 9.5% of the state population.

This post is getting pretty long, so I'm breaking the other demographic data out into multiple posts. Look for the rest of them throughout the day on Monday.