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Milliman·August 12, 2025

Milliman Analysis Forecasts Major Medicaid and Marketplace Enrollment Shifts Following End of Enhanced ACA Subsidies and New Federal Policy Changes

This benchmarking report examines enrollment dynamics in Medicaid and individual marketplace insurance since 2020, finding that subsidized marketplace growth was concentrated among near-poverty populations while Medicaid changes varied significantly by state. With enhanced premium subsidies set to expire and new federal rules on income verification, premium subsidy repayment, and potential Medicaid work requirements taking effect, the analysis projects substantial enrollment volatility in 2026—including an estimated 3.5 million losing individual market coverage. For Medicaid MCOs and state programs, this signals potential membership shifts, redeterminations challenges, and the need to prepare operational systems for new eligibility verification and work requirement administration.

Managed Care · Finance

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This is outside commentary from Milliman, not part of Medicaid Monitor's independently scored news coverage.

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