Meanwhile, Basic Health Plan (BHP) enrollment breaks 2 million nationally.

Whenever I write about BHPs I always throw in a simple explainer about what it is, with an assist from Louise Norris:

Under the ACA, most states have expanded Medicaid to people with income up to 138 percent of the poverty level. But people with incomes very close to the Medicaid eligibility cutoff frequently experience changes in income that result in switching from Medicaid to ACA’s qualified health plans (QHPs) and back. This “churning” creates fluctuating healthcare costs and premiums, and increased administrative work for the insureds, the QHP carriers and Medicaid programs.

The out-of-pocket differences between Medicaid and QHPs are significant, even for people with incomes just above the Medicaid eligibility threshold who qualify for cost-sharing subsidies.

The Basic Health Program (BHP) – section 1331 of the ACA — was envisioned as a solution, although most states did not establish a BHP. Under the ACA (aka Obamacare), states have the option to create a Basic Health Program for people with incomes a little above the upper limit for Medicaid eligibility, and for legal immigrants who aren’t eligible for Medicaid because of the five-year waiting period.

In short, if you earn up to 138% FPL, you enroll in Medicaid; from 138 - 200% FPL, you enroll in a Basic Health Plan policy (BHP); at 200% FPL or higher, you enroll in a Qualified Health Plan policy (QHP).

Federal funding for BHP programs is supposed to be equal to 95% of the total amount of advance premium tax credits (APTC) and cost sharing reduction (CSR) assistance that the enrollees would otherwise have been eligible for had they otherwsie enrolled in a QHP using the ACA exchange.

Of course, the state itself can also throw in additional funding to make the BHP plans more generous if they wish...which is a key point to keep in mind. The coverage has to be at least as affordable and at least as good as a benchmark silver plan with Cost-sharing reduction benefits applied.

There are currently three states which have implemented a version of the BHP program: Minnesota, which revamped their existing "Minnesotacare" program; New York, which calls their version "The Essential Plan;" and Oregon, which just launched their "Bridge Program" last summer.

While BHPs are officially designed for enrollees who earn between 138% - 200% FPL, last year New York expanded their program to residents who earn up to 250% FPL via a waiver process.

In the early years of the ACA, BHP enrollment was so low it was considered an afterthought, even by the Centers for Medicare & Medicaid Services, who often didn't even include BHP enrollees in their enrollment reports, or if they did only gave them a footnote. As the years have gone by, however, BHP enrollment has grown substantially, and of course New York's expansion along with Oregon launching their version helped as well.

The official BHP program enrollment in each state as of the end of the 2025 Open Enrollment Period back in January was a little under 1.8 million.

However, I just checked the latest data in all three states, and since last winter enrollment has grown substantially:

• Minnesota: The state's latest report places Minnesotacare enrollment at 99,633 as of August.
• New York: Total Essential Plan enrollment reached 1,915,035 as of early August.
• Oregon: The Oregon Health Authority enrollment dashboard puts Bridge Plan enrollment at 34,243 as of July.

Combined, that's 2,048,911 Americans enrolled in a BHP program in one of these three states.

it's important to note that BHP funding is directly based on the ACA's subsidy levels (both the APTC & CSR assistance combined), so anything which impacts APTC funding also largely controls BHP funding as well.

So, going forward, any time you hear someone (including myself) talk about the impact of the expiring ACA subsidies on "24 million" ACA exchange enrollees, make sure to mentally bump that total up to 26 million, since BHP enrollees will be negatively impacted as well.