Low-Income ACA Enrollees Shifted Heavily From High-CSR Silver to Bronze in 2026

Key Takeaways

• Silver enrollment fell sharply; bronze rose among low‑income enrollees.
• Average actuarial value dropped from 80% to 76% in 2026.
• Enrollment declined 4.9%; total coverage value fell 10%.
• Washington, Arkansas, Illinois saw gold plans outprice silver.

Summary

In 2026, low‑income ACA marketplace enrollees dramatically shifted from high‑CSR silver plans to bronze, accelerating a multi‑year trend. The average actuarial value (AV) for HealthCare.gov states fell from about 80% in 2025 to 76% in 2026, while total enrollment dropped 4.9%, resulting in a 10% decline in overall coverage value. Strict silver‑loading policies in Washington, Arkansas and Illinois made gold plans cheaper than silver, prompting many to select gold instead. The combined effect leaves vulnerable consumers facing higher out‑of‑pocket costs and a weaker risk pool.

Pulse Analysis

The Affordable Care Act’s marketplace has long relied on cost‑sharing reductions (CSRs) to boost the actuarial value of silver plans for households earning up to 200% of the Federal Poverty Level. By raising silver’s AV to 94% or 87% for the poorest enrollees, CSRs create a middle‑tier option that balances premiums and out‑of‑pocket risk. However, the newly released 2026 Public Use Files reveal a pronounced migration away from these enhanced silver products toward lower‑cost bronze coverage, especially among low‑income participants who depend on CSRs for affordability.

Data show that average AV across HealthCare.gov states slipped from roughly 80% in 2025 to 76% in 2026, while total enrollment fell from 24.3 million to 23.1 million. This double‑digit contraction translates into a 10% reduction in the aggregate coverage value, a signal that both enrollment volume and plan quality are deteriorating simultaneously. The shift is partly driven by strict silver‑loading rules adopted in Washington, Arkansas and Illinois, where subsidies now make gold plans cheaper than silver, prompting 31‑51% of enrollees in those states to opt for gold instead.

For policymakers and insurers, the trend raises red flags. Low‑income households abandoning high‑CSR silver plans face higher deductibles and co‑pays, potentially increasing uncompensated care and eroding the risk pool’s health mix. The decline also underscores the fragility of subsidy structures when state‑level pricing reforms alter plan economics. Continued monitoring and possible adjustments to CSR eligibility or metal‑level pricing may be required to preserve affordable coverage and maintain the ACA marketplace’s long‑term viability.