Final ACA program funding allocations for fiscal year 2025 still aren't available, according to the budget proposal.

The budget proposal shows that total ACA exchange program spending could be $2.1 billion in fiscal year 2026, down 20% from the total for fiscal year 2022.

But most of the drop would be the result of the Trump administration cutting spending on advertising and "navigators," or nonprofit helpers, about 86%, to $72 million.

Spending on the ACA exchange system infrastructure, including exchange information technology systems, the HealthCare..gov call center and compliance systems, would fall just 2.6%, to about $2 billion.

Related: HHS-leaked document indicates HealthCare.gov will still exist in 2026

The federal government's 2026 fiscal year will start Oct. 1.

What CMS really spends on the ACA exchange system will depend on what Congress says, what CMS officials do going forward, and how many insurers continue to offer plans through the exchange system and pay user fees to the exchange program managers.

The ICHRA issue: Employers are now doing something that benefits brokers have dreamed about offering them for decades: Putting cash in accounts that employees can use to buy their own individual health coverage on a guaranteed-issue basis, with no fear of preexisting health conditions affecting the premiums.

Today, employers are offering the "cash for coverage" plans using qualified small employer health reimbursement arrangements, or QSEHRAs, and the more flexible ICHRAs.

Many Republicans in Congress are strong supporters of the ICHRA program.

The One Big Beautiful Tax Bill package — tax and budget package that the U.S. House passed May 22 — includes a new, more flexible version of the ICHRA program: the "custom health option and individual care expense" arrangement program, or CHOICE arrangement program.

Unlike today's ICHRA program, the CHOICE version of the ICHRA program would let employers offer workers a choice between an ICHRA account and ordinary, fully insured health insurance.

The CHOICE program would also let workers keep the pay spent on individual CHOICE program health coverage out of their taxable income. Today, workers must put the income they spend on ICHRA coverage in their taxable income for federal income tax purposes.

For either today's ICHRA program or the CHOICE program in the House package to work, employers and their employees need for an active individual major medical insurance market to continue to exist, either through the ACA exchange system or outside the exchange system.

About 4 million of the 24 million people with individual major medical insurance have coverage purchased outside the ACA exchange system, and some states, including Arkansas, Mississippi, Missouri and Pennsylvania, still had large off-exchange individual major medical insurance markets as recently as 2023, according to data from Mark Farrah Associates,

But, in many states, the ACA exchange market for individual coverage is much more competitive than the off-exchange market, and employers in those states might have a hard time keeping ICHRA plans or CHOICE plans going in 2026 if the ACA exchange system disappeared.

The marketing cuts: One question is what proposed marketing funding cuts and enrollment rule changes would do to the exchange plan risk pool.

Many Republican advocates for the cuts say that the cuts would mainly affect nonprofit outreach programs and expensive TV advertising campaigns that have had little clear impact on exchange plan enrollment.

Defenders of the current CMS marketing support strategy for the exchange program argue that helps keep the program stable by persuading more relatively young, healthy people to pay for coverage.

Naoki Aizawa, an economist at the University of Wisconsin-Madison, and You Suk Kim, an economist at the Federal Reserve Board, recently reported in a paper published in the American Economic Journal: Economic Policy that HealthCare.gov advertising seems to do much more to increase overall exchange plan enrollment than insurers' own ads do.