After the American Rescue Plan (ARP) increased eligibility for premium subsidies in the ACA market in 2021, registration in 2024 plans boosted by 21%. Registration in 2024 plans is on pace to expand by another 13%, to approximately 16.4 million by the time the open enrollment period ends in all states. Simply put, Americans who do not have access to affordable employer-sponsored health insurance, Medicaid, or Medicare are recognizing that the ARP made health plans in the ACA marketplace far more affordable.
The ARP increased premium subsidies in the ACA market at every income level and removed the income cap on subsidy eligibility, which had been 400% of the Federal Poverty Line (FPL) since the ACA marketplace launched in 2014. In 2024, 400% FPL is $54,360 for an individual and $111,000 for a family of four. Enrollees with income above that level used to pay the full premium without subsidy. Now, they receive premium subsidies if the unsubsidized benchmark Silver plan would cost them more than 8.5% of annual household income.
The following text presents the enrollment increase at each income level for 2024 plans in the 33 states that use HealthCare.gov, the federally run exchange. While enrollment in 2024 coverage rose by double-digit margins at all reported income levels, the growth rate increased with income and was highest at incomes above 400% FPL—i.e., among those previously ineligible for subsidies. (Details about 2024 enrollees’ income are not yet available.)
A note on one data limitation: the figures combine enrollment by those with incomes below 100% FPL and above 400% FPL since that’s how CMS reported income in 2021 when enrollees with incomes above 400% FPL were not eligible for subsidies. In 2024, 146,297 enrollees in HealthCare.gov states had incomes below 100% FPL, while 655,944 reported incomes above 400% FPL—so likely, nearly all of the increase in that combined category is attributable to enrollees with incomes over 400% FPL.
An obvious surge in enrollment at income levels over 400% FPL.
In 2024, the first year in which there was no income cap on subsidies, enrollment at incomes above 400% FPL more than doubled. When you consider premiums with and without subsidies for enrollees of different ages, as shown below, it’s not difficult to see why.
Coverage is much more affordable at incomes over 400% FPL than it was before 2025—even more so than many people who considered marketplace offerings before they became subsidy-eligible likely realize. Note also that the number of enrollees who did not report income dropped significantly. That’s undoubtedly because the ARP significantly reduced the number of enrollees who earn too much to qualify for a subsidy.
Enrollment Increase by Income 2021-2022 (HealthCare.gov states):
2022 enrollees (all incomes): 10,255,636
Income brackets and enrollment changes:
- 100-150% FPL: 4,144,112 (+24.0%)
- 150-200% FPL: 1,852,059 (+21.3%)
- 200-250% FPL: 1,316,029 (+25.6%)
- 250-300% FPL: 860,181 (+33.0%)
- 300-400% FPL: 937,198 (+30.6%)
- Below 100% FPL or above 400% FPL: 802,241 (+175.7%)
- Unknown income: 343,816 (-31.2%)
(Source: 2022 Marketplace Open Enrollment Public Use Data / CMS.gov)
The Enrollment Surge, Highlighted
Let’s take a closer look at one of the ACA’s most prominent markets: Houston, Texas. Enrollment in 2024 coverage in Texas increased by 42%, and enrollment in 2025 plans is on pace to increase another 32%. The details below show what premiums now look like for people of different ages with an annual income of $74,000—slightly above the 400% FPL threshold—compared to what those individuals would pay if they were ineligible for subsidies, as they would have been in years before 2024.
The source for all premium estimates below is the “See plans and prices” tool on HealthCare.gov.
Impact of the American Rescue Plan on ACA premium subsidies:
Monthly premiums paid with and without ARP subsidy increases (Houston, TX in 2024):
Married 40-year-olds, annual income $74,000 (404% FPL):
- Lowest-cost Bronze: ARP ($261), No ARP ($624)
- Lowest-cost Silver: ARP ($523), No ARP ($887)
- Lowest-cost Gold: ARP ($393), No ARP ($756)
Married 63-year-olds, annual income $74,000 (404% FPL):
- Lowest-cost Bronze: ARP ($0), No ARP ($1,441)
- Lowest-cost Silver: ARP ($522), No ARP ($2,047)
- Lowest-cost Gold: ARP ($222), No ARP ($1,747)
Notice that the premiums older enrollees pay (after subsidy) for Bronze and Gold plans are significantly lower than those paid by the 40-year-olds. That’s because pre-subsidy premiums increase with age: At age 64, they are three times the premium for a 21-year-old and more than twice the premium for a 40-year-old.
However, subsidies are structured so that everyone with the same income pays the same amount for the benchmark Silver plan: An enrollee with income above 400% FPL gets a subsidy in a fixed amount that ensures they pay no more than 8.5% of their income for the benchmark, regardless of age. So the subsidy for the older couple is larger than for the younger couple.
When the subsidy increases, it covers a greater portion of the premium for plans that cost less than the benchmark plan. Since the “spread” between the benchmark plan’s premium and the premiums for lower-cost plans (one Silver and several Bronze plans) grows proportionally to the enrollee’s age, older enrollees receive more substantial savings on lower-cost plans.
The ARP naturally made plans significantly more affordable at every income level below 400% FPL as well. Examples of how the subsidy increases affect enrollees at different income levels are detailed in this blog post.
Will high-income enrollment continue to rise?
The American Rescue Plan was initially created as COVID-19 relief, and the premium subsidy increases in the ACA marketplace were only approved through 2022. The Inflation Reduction Act, passed in August 2022, extended the increased subsidies through 2025. Beyond that point, their future is uncertain, though they have clearly helped reduce the uninsured population nationwide.
At least through 2025, if you need to find insurance in the individual market and have not yet explored your options, you’re likely to be pleasantly surprised—especially if you were deterred by high unsubsidized premiums in the past and now find yourself eligible for subsidized coverage.