Here's why I keep using the Schrodinger's Cat theme: 2025 Enrollment is already 9% ahead of last year's FINAL tally across 5 states

The Centers for Medicare & Medicaid Services (CMS) has published two 2025 ACA Open Enrollment Period "snapshot reports," both of which had above-the-fold numbers which make it look as though enrollment numbers are lagging significantly behind last year's record-breaking totals:

The Centers for Medicare & Medicaid Services (CMS) is committed to creating a robust Marketplace Open Enrollment process for consumers so they can effortlessly purchase high-quality, affordable health care coverage. CMS reports that nearly 988,000 consumers who do not currently have health care coverage through the individual market Marketplace have signed up for plan year 2025 coverage.

OMG! Last year over 1.6 milllion new enrollees had signed up as of the first snapshot report...over 66% more!

Even this morning's Washington Post/KFF Health News Health Brief made things sound dire:

New and returning sign-ups through healthcare.gov — the federal marketplace that serves 31 states — are well below last year’s rate. New enrollments were just over 730,000 in early December, compared with 1.5 million at the same time last year.

To give consumers in those states more time to enroll, the Centers for Medicare and Medicaid Services extended the deadline to Wednesday to sign up for coverage that starts Jan. 1. (Open enrollment itself ends in most states on Jan. 15, for coverage that would begin Feb. 1.)

As I pointed out both times, however, when you dig deeper into the numbers and adjust them for a true apples-to-apples comparison, the gap isn't nearly as dramatic...

...Next, we have to adjust for another major change from last year: Georgia, which transitioned from being hosted via the Federally Facilitated Marketplace (FFM, or HealthCare.Gov) over to its own full State-Based Marketplace (SBM), Georgia Access.

...When you do this, the actual year over year drop is a bit lower still: down 20.1%.

...and when you also added in auto-renewals for the states which had reported that data as of the press release date, it was conceivable that 2025 Open Enrollment has actually been running ahead of last year.

In other words, 2025 OEP is both 26.5% behind and 2.3% ahead of last year depending on how you look at it.

Well, it's been another two weeks, and there have been several important developments since the last CMS snapshot report:

  • The initial deadline for January 2025 coverage was bumped out by several days in most states
  • Both the initial deadline (12/15) and extended deadline (12/18) have now passed in most states
  • Several state-based exchanges have published more recent enrollment data
  • The ongoing DACA eligibility battle has bounced back & forth a few times (a nominal number of enrollees, but still worth mentioning)

With that in mind, let's see where things stand in the states which have posted more recent enrollment data:

With the caveat that these 4 states only made up 3.5% of total OEP enrollments last year, so far they're collectively running 27% ahead of the same point a year ago, and 10% ahead of last year's final enrollment tally.

Last year saw OEP enrollment jump a whopping 31% over the prior year...nearly 5.1 million people. Many of them came from Medicaid via the Unwinding process which had been playing out over the course of the prior year, and many more from the Unwinding population enrolled after last January's OEP deadline.

The vast majority of those additional enrollees (4.5 million) live in states hosted by the federal exchange, which hasn't reported auto-renewals yet...and my guess is that the vast majority of these folks, who likely have never had ACA exchange coverage before, let themselves be auto-renewed.

UPDATE: Add Nevada to the list of states which have already exceeded their final 2024 OEP totals. With NV included, these 5 states made up 4.0% of all 2024 OEP enrollments:

Advertisement