End Notes
[1] By the end of the year, open enrollment will be almost over in most states, and many people will have decided to drop coverage after seeing large premium increases for their plans. Also, insurers have already finalized rates assuming that the expiration of the premium tax credit enhancements will push out some healthier enrollees, driving up underlying premiums. Congressional Budget Office estimates provided to House leadership. Laura Weiss and Samantha Handler, “Johnson’s To-do List of Tuesday,” Punchbowl News, September 16, 2025, https://punchbowl.news/archive/91625-am/#__thevaultwhydemswantobamacaredealnow.
[2] Jennifer Sullivan and Nicole Rapfogel, “Five Key Changes to ACA Marketplaces Amid Uncertainty Over Premium Tax Credit Enhancements,” CBPP, September 22, 2025, https://www.cbpp.org/research/health/five-key-changes-to-aca-marketplaces-amid-uncertainty-over-premium-tax-credit.
[3] Congressional Budget Office (CBO), “The Estimated Effects of Enacting Selected Health Coverage Policies on the Federal Budget and on the Number of People with Health Insurance,” September 18, 2025, https://www.cbo.gov/publication/61734; Justin Lo et al., “ACA Marketplace Premium Payments Would More than Double on Average Next Year if Enhanced Premium Tax Credits Expire,” KFF, September 30, 2025, https://www.kff.org/affordable-care-act/aca-marketplace-premium-payments-would-more-than-double-on-average-next-year-if-enhanced-premium-tax-credits-expire/.
[4] Centers for Medicare & Medicaid Services (CMS), “Effectuated Enrollment: Early 2025 Snapshot and Full Year 2024 Average,” July 30, 2025, https://www.cms.gov/files/document/effectuated-enrollment-early-snapshot-2025-and-full-year-2024-average.pdf.
[5] CBPP, Beyond the Basics, “Key Facts: Premium Tax Credit,” updated August 2024, https://www.healthreformbeyondthebasics.org/premium-tax-credits-answers-to-frequently-asked-questions/
[6] Lo et al., op. cit.
[7] CMS, op. cit.
[8] Elizabeth Zhang, “ACA Marketplace Policies Softened Coverage Losses From Unwinding of the Medicaid Continuous Coverage Provision,” CBPP, September 9, 2025, https://www.cbpp.org/blog/analyzing-the-census-bureaus-2024-poverty-income-and-health-insurance-data?entry_uuid=73eb89fb-b1fb-4ffb-a915-600e2fdb2548#entry.
[9] Roughly half of enrollees’ races were unknown in 2024 marketplace enrollment data. The estimates cited here are limited to states that use the HealthCare.gov platform and include imputations of missing race and ethnicity data, which greatly improves the usefulness of the data but does not disaggregate beyond broad racial and ethnic categories. Anupama Warrier et al., “HealthCare.gov Plan Selections by Race and Ethnicity, 2015-2024,” Office of the Assistant Secretary for Planning and Evaluation, HHS, October 1, 2024, https://aspe.hhs.gov/reports/healthcaregov-plan-selections-race-ethnicity-2015-2024.
[10] CBPP analysis of American Community Survey. Rose Chu and Benjamin Sommers, “Health Insurance Coverage Changes Since Implementation of the Affordable Care Act: Asian Americans and Pacific Islanders,” Office of the Assistant Secretary for Planning and Evaluation, HHS, May 23, 2021, https://aspe.hhs.gov/reports/health-insurance-coverage-changes-asian-americans-pacific-islanders.
[11] Idaho is excluded due to missing data. CMS, “2025 Marketplace Open Enrollment Period Public Use Files,” May 2, 2025, https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2025-marketplace-open-enrollment-period-public-use-files and “2021 Marketplace Open Enrollment Period Public Use Files,” April 13, 2021, https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2021-marketplace-open-enrollment-period-public-use-files.
[12] Jessica Banthin, Laura Skopec, and Michael Simpson, “Enhanced PTCs Help Older Adults and Those in High-Premium States Afford Coverage,” Urban Institute, September 9, 2024, https://www.urban.org/research/publication/enhanced-ptcs-help-older-adults-and-those-high-premium-states-afford-coverage.
[13] Thomas A. Barthold, Joint Committee on Taxation memorandum dated September 18, 2025, Punchbowl News, https://punchbowl.news/jct-aca/.
[14] Gideon Lukens, “ACA Drove Record Coverage Gains for Small-Business and Self-Employed Workers,” CBPP, July 17, 2024, https://www.cbpp.org/blog/aca-drove-record-coverage-gains-for-small-business-and-self-employed-workers.
[15] Gideon Lukens, “Research Note: 5 Million Small Business Owners and Self-Employed Workers Likely Enrolled in ACA Marketplace in 2025,” CBPP, June 12, 2025, https://www.cbpp.org/research/health/5-million-small-business-owners-and-self-employed-workers-likely-enrolled-in-aca.
[16] CBO, op. cit.
[17] Matthew Buettgens et al., “4.8 Million People Will Lose Coverage in 2026 If Enhanced Premium Tax Credits Expire,” Urban Institute, September 17, 2025, https://www.urban.org/research/publication/48-million-people-will-lose-coverage-2026-if-enhanced-premium-tax-credits.
[18] Ibid.
[19] Claire Heyison, “Marketplace Enrollees Tell Congress: Extend the Enhanced Premium Tax Credits,” CBPP, July 29, 2025, https://www.cbpp.org/blog/marketplace-enrollees-tell-congress-extend-the-enhanced-premium-tax-credits.
[20] Some, but not all, provisions in the rule were temporarily paused by a district court order. Jennifer Sullivan and Nicole Rapfogel, “Five Key Changes to ACA Marketplaces Amid Uncertainty Over Premium Tax Credit Enhancements,” CBPP, September 22, 2025, https://www.cbpp.org/research/health/five-key-changes-to-aca-marketplaces-amid-uncertainty-over-premium-tax-credit; U.S. District Court for the District of Maryland, “Memorandum Opinion, City of Columbus et al. v. Robert F. Kennedy, Jr. et al., Civil No. 25-2114-BAH, August 22, 2025, https://democracyforward.org/wp-content/uploads/2025/08/35-City-of-Columbus-memorandum-opinion.pdf.
[21] CBPP, “Marketplace Enrollees Face Steep Premium Increases Unless Tax Credit Enhancements Are Extended,” https://www.cbpp.org/research/resource-lists/marketplace-enrollees-face-steep-premium-increases-unless-tax-credit.
[22] In 2025, half of all PTC enrollees with incomes above 400 percent of poverty have incomes between 400 and 500 percent of poverty, or between about $60,000 to $75,000 for an individual (using 2024 poverty guidelines), the Urban Institute estimates. Jessica Banthin, Laura Skopec, and Michael Simpson, “Enhanced PTCs Help Older Adults and Those in High-Premium States Afford Coverage,” Urban Institute, September 9, 2024, https://www.urban.org/research/publication/enhanced-ptcs-help-older-adults-and-those-high-premium-states-afford-coverage.