HHS has proposed a Marketplace Integrity and Affordability rule that will result in decreased marketplace enrollments in 2026, ranging from 750,000 to 2,000,000 fewer enrollees than otherwise expected. They further estimate this reduction in enrollment will lead to a reduction in average claims of between -0.9% and -5.4%. This outcome is counterintuitive to most pricing actuaries since a decrease in enrollment typically results in a worsening risk pool. The Marketplace Integrity rule is adding significant hassle factors to signing up and tightened special enrollment period rules that prior research indicates will likely lead to higher claims costs per member.
