CNC · 10-Q · 2026Q1 · Full report

Marketplace APTC changes

CENTENE CORP · 2026-04-28 · Importance 59 · Surprise 60

Enhanced Advance Premium Tax Credits (APTCs) initially expanded under ARPA and extended by the Inflation Reduction Act expired at the end of 2025, reducing subsidy levels available in the Health Insurance Marketplace. The Marketplace Integrity and Affordability Final Rule (published June 25, 2025) tightened program integrity (for example, repeal of certain Special Enrollment Periods effective August 25, 2025) and several provisions have been stayed pending litigation. The OBBBA added further restrictions effective January 1, 2026, requiring repayment to the IRS for mis‑estimated income APTCs and prohibiting receipt of APTCs where enrollment occurs via an income‑related Special Enrollment Period; Centene attributes lower Marketplace membership and higher projected Marketplace morbidity in 2026 to the combined effect of these changes. Centene disclosed it adjusted 2026 Marketplace pricing covering 95% of Marketplace membership and expects elevated morbidity and market contraction to persist.

Key facts

• Beginning January 1, 2026 under OBBBA, individuals who mis-estimate projected income must reimburse the IRS for full excess APTC received and are prohibited from receiving APTCs if they enroll through a Special Enrollment Period associated with income.
• The Final Rule published June 25, 2025 repealed the Special Enrollment Period for those under 150% of the FPL beginning August 25, 2025, and several provisions of the Final Rule have been stayed due to litigation.
• The combined effect of expiration of Enhanced APTCs and the Final Rule reduced 2026 Marketplace membership in Q1 2026 compared to 2025.
• The determination of the final balance of the 2025 net risk adjustment payable will be made as of June 2026.
• The 2026 risk adjustment estimate will be updated as industry relative member morbidity data is received from Wakely throughout 2026.

Impact estimates