US health coverage fell 2.8% as ACA subsidy expiration hit individual market
Self-funded employer plans bucked the trend, adding 1.1 million members in the second quarter of 2026
US health coverage fell 2.8% as ACA subsidy expiration hit individual market
GROUP BENEFITS
By Mark Rosanes
07 Oct 2026

Total US health insurance coverage fell 2.8% in the 12 months through June 30, to approximately 312.5 million people. The losses were concentrated in Medicaid, the individual market, and fully insured employer plans. Medicare Advantage and self-funded employer arrangements both grew. The figures come from Mark Farrah Associates (MFA), a data aggregator drawing on statutory financial filings from the National Association of Insurance Commissioners (NAIC), Centers for Medicare & Medicaid Services (CMS), and state agencies.

The movement ran in opposite directions across segments. Medicare Advantage added 700,000 members year over year to reach approximately 35.1 million, a 2% gain. Employer-group administrative services only (ASO) plans gained just over 1.1 million members to reach approximately 135.8 million, up 0.8%. MFA notes its ASO figures are estimates derived from company and industry resources.

Three segments declined. Medicaid fell by 4.1 million members. The individual market lost more than 4.5 million. Fully insured employer-group risk plans shed approximately 2 million members.

The self-funding shift

The ASO gain and the employer-group risk decline describe a migration that has been underway for years. Employer-group risk membership fell from approximately 48.8 million in Q2 2025 to 46.7 million in Q2 2026, a 4.3% drop.

ASO plans now account for 43.5% of total US health enrollment. That makes self-funded arrangements the largest single coverage segment in the country, ahead of fully insured employer plans, Medicaid, Medicare Advantage, and the individual market.

Employers have moved toward self-funding for several reasons. Self-funded plans give employers direct visibility into claims data and more flexibility in plan design. They are also exempt from state-mandated benefit requirements that apply to fully insured plans. Each shift from a risk-based plan to an ASO arrangement brings a different advisory relationship and a stop-loss procurement conversation that did not exist before. It also places the employer in a different compliance framework.

That shift is now happening in a more demanding regulatory environment. The CAA 2026 requires PBMs to pass through rebates to self-funded plan sponsors. It also mandates detailed compensation disclosures to plan fiduciaries. ASO employers are taking on more oversight obligations at the same time their numbers are growing.

The individual market and its employer ripple

The individual market fell 17.2%, from 26.5 million members to 22 million, between Q2 2025 and Q2 2026. MFA attributes the drop primarily to the expiration of enhanced federal premium tax credits at the end of 2025.

KFF reported that the average ACA marketplace deductible rose 37% in 2026 to $3,786, up from $2,759 in 2025. Consumers shifted toward lower-premium bronze plans after the subsidies expired.

The downstream effect on employer plans is still working through the system. Before the subsidies lapsed, Urban Institute and Commonwealth Fund modeling estimated that roughly 3.2 million people would shift toward employer-sponsored coverage as individual market premiums became unaffordable.

That is a pre-expiration projection, as comprehensive employer enrollment data for 2026 is not yet fully available. If the shift is occurring at that scale, it is arriving at employer plans already navigating rising renewal costs. Small and mid-market employers whose workers previously relied on marketplace coverage are absorbing that pressure first.

The Medicaid decline of 4.1 million members reflects post-pandemic enrollment unwinding and new eligibility restrictions under the 2025 reconciliation law. Work requirements for Medicaid expansion enrollees are set to take effect in January 2027.

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