Breaking: CMS posts claimed 2026 Open Enrollment: 22.8M QHPs, down 3.5% y/y so far

The Centers for Medicare & Medicaid Services (CMS) just published the second official 2026 Open Enrollment Period snapshot report:

The Centers for Medicare & Medicaid Services (CMS) reports that 22.8 million consumers have signed up for 2026 individual market health insurance coverage through the Marketplaces since the start of the 2026 Marketplace Open Enrollment Period (OEP) on November 1, 2025. This includes 15.6 million Marketplace plan selections in the 30 states using the HealthCare.gov platform for the 2026 plan year and 7.2 million plan selections in the 20 states and the District of Columbia with state-based Exchanges (SBEs) that are using their own eligibility and enrollment platforms.

Total nationwide plan selections include 2.8 million consumers who are new to the Marketplaces for 2026, and 20.0 million consumers who had active 2025 coverage and selected a plan for 2026 coverage or were automatically re-enrolled.

As usual, I'll start out with the top line numbers, compared to the same point last year...with one important difference: I've had to adjust the breakout to account for ILLINOIS moving from the federal exchange (HealthCare.Gov) onto its own state-based exchange (Get Covered Illinois):

Overall, total enrollment is down about 3.5% vs. the same point a year ago (roughly 834,000 enrollees nationally). I should note that there's also one less day included this year for both the federal exchange (thru Jan. 3rd instead of Jan. 4th) and the state-based exchanges (Dec. 27th instead of Dec. 28th). I haven't bothered to adjust for those, however, since the difference is likely nominal at most.

• NEW enrollment is down 375,000 people, or 11.8%
• RENEWING enrollees are down by 459,000 people, or 2.2%

It's the latter group which is almost certainly wildly misleading, as the odds are high that a good half of the ~20.4 million existing enrollees who renewed their policies did so via passive auto-renewal, which, as I warned about a couple of weeks ago, means that many of them either terminated their policies the moment they got over the sticker shock of their January premium invoice or will only be able to pay the premium for a few months before having to do so.

In other words, while the official year over year drop is "only" 834,000 people so far (remember, there's still time for residents of 49 states +DC to sign up for coverage starting February 1st), the actual drop in enrollment is likely to be several times as much when the dust settles.

Today's "Snapshot Report" also breaks out the enrollment data so far by state; here's what it looks like compared to the same point last year:

A few noteworthy states (remember, this could change in the time remaining):

• Total enrollment is lower (so far) in 39 states, higher in 11 +DC

• New Mexico enrollment is up a whopping 19.5% thanks to the state backfilling 100% of the lost federal tax credits for 100% of eligible enrollees!

• District of Columbia enrollment is up 9.7%, likely due to the District abandoning their 215% FPL Medicaid waiver in favor of a Basic Health Plan program (which only covers enrollees earning up to 200% FPL)

• North Carolina is seeing the highest drop in enrollment so far, down over 21%; some of this may be due to their Medicaid expansion program still ramping up, although that should be fully baked in by now, I would think

• Other states with double-digit drops in enrollment: Ohio, West Virginia, Delaware, Indiana, Oklahoma, Oregon, Arizona, Georgia, Missouri & Tennessee

In addition:

• District of Columbia's BHP enrollment (Healthy DC) as of 12/27: Unknown
• Minnesota's BHP enrollment (MinnesotaCare) as of 12/27: 106,204
• New York's BHP enrollment (Essential Plan) as of 12/27: 1,719,660*
• Oregon's BHP enrollment (Bridge Program): 34,609

(NY's BHP enrollment likely plummeted as of Jan. 1st, however, as they had to downgrade the program eligibility from 250% FPL to 200% FPL.)

UPDATE: Here's The Graph® as of today; the SBM total is slightly different than the tallies above because this includes more recent data for a few states (remember, the CMS report only runs through 12/27 for the state-based exchanges). In fact, the SBM total is already 7,829 lower than the official total above, a small red flag of what I warned about a couple of weeks ago...