APTC

Every year around this time I start my annual individual & small group market rate filing analysis project. This involves spending months painstakingly tracking every insurance carrier rate filing for the upcoming year to determine just how much average insurance policy premiums on the individual market are projected to change.

Carriers tendency to jump in and out of the market, repeatedly revise their requests, and the confusing blizzard of actual filing forms sometimes make it next to impossible to find the specific data I need.

The actual data I need to compile my estimates are actually fairly simple, however. I really only need three pieces of information for each carrier:  How many effectuated enrollees they have in ACA-compliant policies this year; the average projected rate change for those policies; and, ideally, a breakout of the rationale behind the changes.

Usually the reasons given are fairly vague things like "increased morbidity" (ie, a sicker risk pool) or the like. Sometimes, however, there's a very specific reason given for some or all of the premium changes. Major examples of this include:

Originally posted 1/05/2025

Texas has ~3.9 MILLION residents enrolled in ACA exchange plans, 95% of whom are currently subsidized. I estimate they also have perhaps ~67,000 unsubsidized off-exchange enrollees.

Combined, that's over 4.0 MILLION Texans, although although assuming the national average 6.6% net enrollment attrition rate applies, current enrollment would be back down to more like ~3.8 million statewide.

I don't want to get out over my skis here; a single Senator saying that she supports something in an interview is a far cry from them actually voting to do so, especially when you'd need several more members of both the House and Senate (including the leadership of both chambers) to even hold that vote.

Even so, this is still a pretty significant development, given how thin the odds are of the improved subsidies included by the IRA getting extended are at the moment.

This is from an interview with Alaska GOP Senator Lisa Murkwoski published by the Alaska Beacon yesterday:

Nathaniel Herz: On the specific issue of the enhanced tax credits for the premiums for the individual marketplace health insurance plans — it seems like there is a real question about whether those continue...

Originally posted 12/24/24

Ohio has around ~583,000 residents enrolled in ACA exchange plans, 91% of whom are currently subsidized. I estimate they also have another ~25,000 unsubsidized off-exchange enrollees.

Combined, that's ~609,000 people, although assuming the national average 6.6% net enrollment attrition rate applies, current enrollment would be back down to more like 568,000 statewide.

Originally posted 12/22/24

Florida has over ~4.7 MILLION residents enrolled in ACA exchange plans, 97% of whom are currently subsidized. I also estimate they have perhaps ~112,000 unsubsidized off-exchange enrollees.

Combined, that's over 4.8 million people, or a stunning 20.3% of their total population. 1 in 5 Floridians are enrolled in ACA exchange healthcare coverage (assuming CMS's 6.6% net national attrition rate applies to Florida specifically, the actual number of current enrollees is more like 4.5 million, or 19% of the state population).

Originally posted 12/16/25

Wisconsin has around ~293,000 residents enrolled in ACA exchange plans, 98% of whom are currently subsidized. I estimate they also have another ~19,000 unsubsidized off-exchange enrollees.

Combined, that's ~333,000 people, although assuming the national average 6.6% net enrollment attrition rate applies, current enrollment would be back down to more like 311,000 statewide.

Over at the JAMA Network, KFF Executive VP for health policy Larry Levitt has a piece which lays out the most likely actions (or in one case, lack of action) that the incoming Trump Administration & Republican-controlled Congress will take now that they have a second shot at repealing the Affordable Care Act:

With many tax cuts from the 2017 Tax Cuts and Jobs Act expiring at the end of 2025, a high-profile Congressional debate over extending those tax reductions and enacting new ones is likely. There will be pressure from some in Congress for spending cuts to help pay for those tax cuts. Trump has said that Social Security and Medicare cuts are off the table, and defense reductions are unlikely as well. That means almost half of federal spending would be protected from cuts, leaving Medicaid, which is the next largest source of federal spending, and the ACA as prime targets for spending cuts. The math is inescapable.

Not that this should surprise anyone, but it's good to have the Congressional Budget Office (CBO) formally chime in:

Re: The Effects of Not Extending the Expanded Premium Tax Credits for the Number of Uninsured People and the Growth in Premiums

Dear Chairman Wyden, Ranking Member Neal, Senator Shaheen, and Congresswoman Underwood:

You have asked the Congressional Budget Office to discuss the effects on health insurance coverage and premiums that will result from not extending—either for one year or permanently—the expanded premium tax credit structure provided in the American Rescue Plan Act of 2021 (ARPA, Public Law 117-2).

ARPA reduced the maximum amount eligible enrollees must contribute toward premiums for health insurance purchased through the marketplaces established by the Affordable Care Act, and it extended eligibility to people whose income is above 400 percent of the federal poverty level (FPL). Those provisions were extended through calendar year 2025 in the 2022 reconciliation act (P.L. 117-169).

 The 2025 ACA Open Enrollment Period (OEP) officially begins on November 1st.

This is the best OEP ever for the ACA for several reasons:

  • A dozen states are either launching, continuing or expanding their own state-based subsidy programs to make ACA plans even more affordable for their enrollees;

*Note: There's still some uncertainty about this, as 19 Republican Attorneys General have filed a lawsuit to block this, and oral arguments were heard just a week or so ago, so it's conceivable that an injunction will be placed before November 1st.

Update 12/09/24: As expected, a federal court has shot down the eligibility of DACA recipients to enroll in ACA exchange coverage in the 19 states involved in the lawsuit. In theory the roughly 2/3 of DACA recipients living in the other 31 states +DC should still be eligible.

Update 12/19/24: OK, never mind: Another federal court has put a stay on the DACA enrollment injunction, so for the moment DACA recipients can enroll in every state.

Update 12/23/24: Rhode Island has extended their 2025 Open Enrollment period all the way out through the end of February due to the nasty security breach of RIBridges, their social services IT system. Anyone who enrolls thru 2/28/25 will have their coverage made retroactive to January 1st.

And remember, millions of people will be eligible for zero premium comprehensive major medical policies.

If you've never enrolled in an ACA healthcare policy before, or if you looked into it a few years back but weren't impressed, please give it another shot now. Thanks to these major improvements it's a whole different ballgame.

Here's some important things to know when you #GetCovered for 2025:

Back in June, I ran a state-by-state analysis which provided estimates of just how much various households would see their net individual market premiums jump starting in 2026 if the upgraded financial subsidies originally included in the American Rescue Plan Act (and later extended by the Inflation Reduction Act) are allowed to expire at the end of 2025, as is currently scheduled to happen without legislative action.

This week, the Robert Wood Johnson Foundation (RWJF)* has published their own take on the financial impact on enrollees if the IRA subsidies are allowed to expire. In this case, however, they're approaching it from a slightly different angle: They're focusing specifically on the approximately 1.7 million ACA exchange enrollees who earn more than 400% of the Federal Poverty Level (FPL).

*Disclosure: RWJF is a sponsor of this website.

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