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ACA Marketplace Enrollment Declines in 2026: Coverage Shifts and Implications for Providers

By Sukrti Thonse & James A. Robertson on March 24, 2026
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Early federal enrollment data for the 2026 Affordable Care Act (ACA) marketplace plan year indicates a meaningful decline in coverage following the expiration of enhanced premium tax credits, which may have significant implications for hospitals and providers as coverage affordability pressures grow and payer mix volatility increases.

Enrollment Declines Following Subsidy Expiration

As of early January 2026, approximately 22.8 million individuals had enrolled in ACA marketplace coverage, compared with 24.2 million enrollees at the end of the 2025 enrollment cycle, a 5.8% decline in coverage, with 1.4 million fewer enrollees overall.

While enrollment remains open in some states, these figures represent the first major data point illustrating the impact of the expiration of enhanced federal premium tax credits, which had substantially lowered coverage costs in recent years. Importantly, the FY2026 appropriations bill did not extend these enhanced subsidies, meaning many consumers are now facing significantly higher out-of-pocket premium costs.

Current projections suggest that premiums for many enrollees may more than double, on average, in comparison to 2025 costs. Although a bipartisan group of lawmakers continues to discuss potential legislative extensions, no such measure has been enacted to date.

State-Level Enrollment Trends

State-reported enrollment data released by the Centers for Medicare & Medicaid Services (CMS) on January 28, 2026, show uneven but concerning shifts across markets, with several large federally facilitated marketplace states experiencing notable enrollment declines, including Florida, North Carolina, and Ohio.

Other states, including California, Colorado, Minnesota, New Mexico, Idaho, Virginia, and Pennsylvania, reported strong enrollment totals in early snapshots, although year-over-year comparisons remain incomplete.

Overall, the available data suggests a broad downward pressure on coverage uptake across multiple states, rather than isolated market fluctuations.

New Jersey Marketplace Trends

The national coverage shifts are particularly relevant for New Jersey, which operates its own state-based exchange through GetCoveredNJ. In recent years, New Jersey saw record marketplace participation, with more than 500,000 residents enrolled in 2025 coverage, driven in part by enhanced federal subsidies and state outreach initiatives.

However, with the expiration of those subsidies entering the 2026 plan year, many residents are now facing higher net premiums. In response, New Jersey extended its open enrollment period through January 31, 2026, to allow additional time for consumers to evaluate coverage options.

Even so, early data suggests notable shifts in consumer behavior. Among individuals actively shopping for plans, the selection of Silver plans declined from approximately 83% in 2025 to 69% in 2026, while Bronze plan selections increased from 16% to 30%.

At the same time, the share of consumers receiving financial assistance that reduced premiums to $10 per month or less dropped from 48% in 2025 to just 10% in 2026. These changes suggest that consumers are responding to higher premiums by selecting lower-cost plans with higher deductibles and cost-sharing obligations.

Implications for Hospitals and Providers

For healthcare providers, these coverage trends should raise concerns. Even when patients remain insured, higher deductibles and increased cost sharing may lead to delayed care, increased uncompensated care, and growing patient bad debt.

Hospitals and health systems should anticipate continued potential payer mix volatility and greater patient financial responsibility as these market shifts continue to unfold.

Photo of Sukrti Thonse Sukrti Thonse

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and…

Associate, Corporate and Healthcare

Sukrti supports clients across a broad range of corporate and regulatory matters, advising at all stages of the business lifecycle with a strong concentration in healthcare and healthcare-adjacent industries. She regularly counsels physicians, medispas, multi-state provider groups, hospitals, and private equity sponsors on compliant corporate structuring, operational strategy, and growth initiatives. She provides guidance to healthcare start-ups, physician practices, and hospital systems on day-to-day operational, regulatory, and strategic matters, and assists clients in navigating complex and novel regulatory issues in highly regulated, multi-jurisdictional environments, including multi-state regulatory compliance and expansion.

In her corporate practice, Sukrti assists with the formation and capitalization of business structures and prepares key documents for fundraising, financing, and investor negotiations. She provides support on M&A transactions and in the structuring and implementation of Management Services Organization-Professional Corporation (MSO–PC) and Friendly PC models, ensuring compliance with Corporate Practice of Medicine (CPOM) doctrines, fee-splitting laws, and state ownership restrictions. Her work frequently involves advising on management services arrangements, equity structuring, rollover investments, and platform acquisitions involving physician-owned entities and private equity-backed healthcare companies.

Sukrti also has significant experience in physician and provider contracting, including drafting and negotiating employment agreements, independent contractor arrangements, professional services agreements, and compensation models (including wRVU-based structures), with careful attention to regulatory compliance and commercial reasonableness. Her practice includes coordinating regulatory due diligence and assisting with disclosure requirements, including for entities operating in FDA-regulated sectors.  She regularly structures and negotiates compensation arrangements with physicians in connection with employment and exclusive contracting arrangements, medical directorships, physician recruitment initiatives, office and equipment leases, and other key operational documents that support healthcare delivery and scalable platform growth.

She has developed particular strength in healthcare privacy and HIPAA compliance and works closely with firm partners to advise on federal and state regulatory frameworks. Sukrti regularly conducts multi-state regulatory analyses, including 50-state surveys addressing licensure, supervision, telehealth, reimbursement, and scope of practice considerations, enabling clients to expand across jurisdictions while mitigating regulatory risk.

Results may vary depending on your particular facts and legal circumstances.

Contact information:

sthonse@greenbaumlaw.com | 732.476.2480 | vCard

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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Photo of James A. Robertson James A. Robertson

Partner and Practice Leader, Healthcare

Jim serves as trusted counsel to the entire healthcare sector. His practice spans the full spectrum of legal, regulatory, and corporate challenges facing healthcare entities.

With a deep technical command of reimbursement and payer strategy, Jim regularly represents…

Partner and Practice Leader, Healthcare

Jim serves as trusted counsel to the entire healthcare sector. His practice spans the full spectrum of legal, regulatory, and corporate challenges facing healthcare entities.

With a deep technical command of reimbursement and payer strategy, Jim regularly represents hospital systems and providers in high-stakes Medicare, Medicaid, and charity care subsidy matters. He possesses particular expertise in navigating disproportionate share hospital (DSH) and graduate medical education (GME) issues before state agencies and the federal Provider Reimbursement Review Board (PRRB). Jim further ensures the long-term sustainability of provider-payer relationships by negotiating complex Medicare Advantage and Managed Medicaid risk-sharing arrangements.

In the transactional arena, Jim provides comprehensive representation for mergers, acquisitions, joint ventures, and divestitures. He serves a diverse array of industry leaders, including for-profit and nonprofit hospital systems, academic medical centers, pharmaceutical companies, integrated delivery networks (IDNs), physician practices, and healthcare private equity funds. Jim is instrumental in the structural development of Clinically Integrated Networks (CINs), Accountable Care Organizations (ACOs), and Multiple Employer Welfare Arrangements (MEWAs), frequently securing necessary certifications from the New Jersey Department of Banking and Insurance (DOBI). His work encompasses the establishment and sale of individual and group practices, ambulatory surgery centers, nursing homes, and assisted living facilities, as well as the negotiation of executive contracts, recruitment initiatives, medical directorships, hospital department management, and office or equipment leases.

To mitigate operational risk, Jim guides clients through the development of robust corporate compliance programs and manages internal audits, government inquiries, and voluntary self-disclosures. His counsel ensures that provider arrangements satisfy the Stark Law, the federal Anti-Kickback Statute (AKS), and New Jersey’s Codey Law. He assists clients in seeking advisory opinions, obtaining Certificates of Need, and securing transaction approvals from the New Jersey Department of Health and the Attorney General under the Community Healthcare Asset Protection Act (CHAPA). His counsel ensures compliance with the Corporate Practice of Medicine (CPOM) doctrine and federal mandates including HIPAA, HITECH, the ACA, and Emergency Medical Treatment and Labor Act (EMTALA)—from drafting Business Associate Agreements (BAAs) to managing medical record retention and the physical or electronic storage of medical records.

Jim’s advocacy extends to medical staff matters, where he designs state-of-the-art bylaws and provides guidance on fair hearing requirements and strategic initiatives. Finally, he represents healthcare entities in business-critical litigation, including provider-payor disputes, restrictive covenant matters, and medical staff privileging hearings. By combining this granular knowledge of reimbursement and regulatory compliance with a veteran litigator’s perspective, Jim provides the strategic foresight necessary to navigate the administrative and operational hurdles of the modern healthcare landscape.

Results may vary depending on your particular facts and legal circumstances.

Contact information:

jrobertson@greenbaumlaw.com | 973.577.1784 | vCard | LinkedIn

For more information visit the Greenbaum, Rowe, Smith & Davis LLP website.

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  • Posted in:
    Health Care and Life Sciences
  • Blog:
    Healthcare Perspectives
  • Organization:
    Greenbaum, Rowe, Smith & Davis LLP
  • Article: View Original Source

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