ACA exchange enrollment beat early forecast by 25%

The ACA exchange system was serving 19.2 million exchange plan enrollees as of April 15. That was down 15% from the enrollee count recorded a year earlier, but it was 25% higher than the 15.4 million enrollee forecast that officials posted in June 2025. It also was 8.5% higher than the 17.7 million enrollee forecast that officials posted four months ago.

Related: Trump administration prepares to keep ACA public exchange system alive in 2027

So, why is exchange use so high?

One reason might be enrollment fraud, the HHS analysts said.

The analysts noted, for example, that 1 million enrollees lack Social Security numbers.

Many of the enrollees in the lowest income category, who face no out-of-pocket cost for premiums, submit no claims.

Those figures suggest that as many as 2.6 million of the enrollees may have lied about their income, may not exist or may not know that a broker signed them up for coverage, the analysts said.

But the analysts also included a figure showing that exchange use by families with income over 250% of the federal poverty level, who pay a significant amount for premiums, has increased 69%, to 6.6 million, over the past five years.

What it means: For employers, the big question may be whether employees who lack access to a traditional employer-sponsored group health plan are more likely to use the ACA exchange system to get covered or to buy individual major medical insurance or other coverage arrangements off-exchange.

A year ago, ICHRA program marketers seemed to be optimistic about the idea of building connections with ACA exchange programs.

This year, ICHRA promoters appear to be focusing more tightly on helping employees with ICHRA cash buy individual or family coverage away from the ACA exchange system, in part because of ACA premium subsidy rules that make buying coverage off-exchange a better deal for many people.

But the resilience of ACA exchange plan enrollment may be a sign that the ACA exchange system could still make a comeback in the ICHRA market.

The headwinds: ACA exchange managers and the health insurers that put products on the exchange shelves knew going into the annual enrollment period for 2026 coverage that they could face two major sales challenges.

One headwind was "market integrity efforts": The administration of President Donald Trump has been trying to set tougher application-checking requirements and other requirements, to reduce the number of phantom enrollees and enrollees who lie on their applications to maximum premium subsidy support.

Another headwind was a decision by the Trump administration and Republicans in Congress to let a temporary ACA premium subsidy boost provided in response to the COVID-19 pandemic expire.

The expiration of the subsidy boost meant that a family of four with an income of $200,000 and parents in their 50s might have seen out-of-pocket costs for mid-tier coverage increase to more than $50,000 this year, from less than $10,000 last year.

But one moderating factor was that access to relatively rich levels of subsidies for people with income under 400% of the federal poverty level kept out-of-pocket costs below $50 per month for about 60% of 2025 enrollees who were trying to keep their health coverage in place.