The Department of Health and Human Services report released June 26, 2026, found that most people newly enrolled in ACA Exchange plans since enhanced subsidies began have qualified for zero-premium coverage. That matters because those enhanced subsidies are set to expire at the end of 2025, pushing monthly costs sharply higher for millions of current enrollees.

Total Exchange enrollment for 2026 reached 23.1 million, with people selecting or being automatically re-enrolled through HealthCare.gov during an open enrollment period that ran through January 15, 2026. The figure sits near the program's all-time high, sustained largely by a subsidy structure that has effectively brought premiums to zero for a large portion of eligible people.

Who Gained — and What They Stand to Lose

The concentration of enrollment growth among people eligible for zero-premium plans carries direct policy consequences. When enhanced credits expire, these enrollees will face the steepest relative increase: jumping from $0 monthly to any dollar amount creates a behavioral shock different from a rate increase for someone already paying several hundred dollars a month. Research shows this group — largely lower-income enrollees who qualified under expanded subsidy thresholds — tends to drop coverage quickly when premiums rise.

An ASPE analysis from January 2025 quantified how many people gained coverage because of enhanced subsidies between 2021 and 2024. That baseline matters for measuring how many drop out after expiration. The June 2026 enrollment report shows aggregate enrollment stayed near record levels through the most recent open enrollment, even as the expiration deadline approached.

The Trump Administration's Alternative

President Trump has outlined a plan to replace government subsidies with direct payments to consumers, according to Reuters. The administration has not published full details on how the payments would work, who would qualify, or how much people would receive. It is also unclear whether Congress will act on the proposal before the subsidy cliff arrives.

The timing matters operationally. Insurance companies set Exchange premiums on an annual cycle and need regulatory clarity well before open enrollment begins in the fall to price plans accurately. If a replacement framework is not enacted and implemented before the relevant rate-setting deadlines — typically late summer — carriers will price plans for 2026 and beyond using the post-enhanced-subsidy baseline. That means higher premiums will appear in the market regardless of what Congress does later.

What the Enrollment Numbers Actually Tell Us

The concentration of zero-premium enrollees also shapes how analysts read headline enrollment figures. A number like 23.1 million can look stable until you break it down. If the group most sensitive to premium changes — people currently paying nothing — exits at high rates after expiration, the total could contract sharply even if higher-income enrollees stick around. That imbalance makes the ASPE composition finding important: it suggests the headline number may be more fragile than its absolute size indicates.

Staff tracking this issue will watch two things in the coming months: first, whether Congress extends enhanced subsidies or enacts a replacement before the year ends; second, how insurance companies respond in their preliminary rate filings for the next plan year. Those filings will signal what insurers expect enrollment to look like without enhanced credits — or with whatever replacement policy emerges.

For now, the record shows a program that grew substantially under a specific subsidy structure, with most of that growth concentrated among people most exposed to expiration.