Who Paid, and Who Stayed? Early 2026 Enrollment Trends in the Individual Market

“A new report from Wakely Consulting Group, an HMA Company, models changes to the 2026 ACA market enrollment due to the loss of federal subsidies. Findings suggest a larger drop in ACA marketplace enrollment – lower than some feared, but higher than the CBO analysis.  Download Full Report – “Based on unique data collection from 80% of the Affordable Care Act (ACA) individual market, Wakely Consulting Group, a Health Management Associates, Inc., Company, estimates a material reduction in enrollment for 2026, ranging on average from 17% to 26% in total. This decrease will likely cause a deterioration in the risk pool in 2026 relative to 2025. We estimate that morbidity could be, on average, between 2.9% and 6.5% worse. Coupled with significant changes in market composition, these impacts introduce considerable uncertainty for issuers as they develop 2027 premium rates. This report examines premium payment patterns among individual market enrollees—who paid, and who did not—in the early months of 2026 and explores potential implications for the remainder of the plan year and beyond. The ACA individual market in 2026 experienced a significant upheaval. The expiration of enhanced premium tax credits, changes in premium tax credit eligibility as a result of recent legislation, increased costs because of high trend and inflation, rate correction from potential historical underpricing, and general uncertainty resulted in the largest net premium increase since the initial implementation of the ACA. The general expectation is that these changes could dramatically shrink the size of the individual market. The Congressional Budget Office (CBO) projected the individual market would decline by approximately 20%, from an average enrollment of 25.4 million in 2025 to an average enrollment of 20.0 million in 2026; however, early indications from Marketplace Open Enrollment Plan (OEP) selection data are that enrollment decreased by only 5% approximately. So, what can we make of this discrepancy between CBO projection and OEP data? One possible explanation is that the forecasted enrollment decreases for 2026 were overstated, and the anticipated declines may not materialize. Alternatively, topline plan selection data may present an incomplete story because they include enrollees who did not—or could not—pay their 2026 premiums. If this is the case, actual attrition in the individual market in 2026 could be larger than what was reported through OEP data. The full extent of attrition in the individual market could still be forthcoming. Wakely conducted a unique study to evaluate the number of people who paid their first premiums across the entire individual market (both on and off Exchange) in 2026 and other corresponding market shifts. This dataset includes enrollment and premium data from participating issuers in 2025 and January 2026, representing over 30 individual markets (including two merged markets) and an estimated 80% of the total individual market. We analyzed January 2026 premium payment rates, shifts in market composition, and changes in member demographics. These insights enabled us to estimate potential ranges of market enrollment reductions and corresponding morbidity impacts in 2026.”

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