The Affordable Care Act (ACA) has been a hot topic of debate in Washington, with a particular focus on reforming the subsidy system. More than a decade after its implementation, the ACA’s subsidy structure is under scrutiny, especially in light of the changes made during the pandemic. The question of whether to extend the enhanced premium subsidies introduced during the pandemic has brought attention to the fundamental issues within the ACA’s subsidy system.
Originally, the ACA’s premium tax credits were designed around an income-based formula, where households purchasing a benchmark silver plan contributed a fixed percentage of their income, with federal subsidies covering the rest. This system targeted assistance towards lower- and middle-income households below 400 percent of the federal poverty level. However, this approach had implications such as shielding households from price increases, limited competitive pressure on insurers to restrain premiums, and making coverage relatively expensive for unsubsidized enrollees.
During the pandemic, Congress made significant changes to the subsidy structure by removing the income cap and reducing required household contributions across income levels. This led to a surge in enrollment but also a sharp increase in federal spending, as the government absorbed most premium growth. The rapid growth of zero-premium plans also raised concerns about unauthorized enrollments and aggressive steering by third-party brokers.
As policymakers debate whether to extend these changes, the underlying structure of the subsidy design is coming under renewed scrutiny. One proposed improvement is a “defined contribution” model, where federal subsidies are tied to a benchmark plan and grow predictably each year, encouraging insurers to manage premiums relative to the benchmark. This approach aligns with how other insurance markets operate and could make federal spending more predictable.
Another proposed improvement involves aligning consumer incentives with program financing by allowing households to benefit from cost-conscious choices. By depositing part of the savings into portable accounts that can be used for various healthcare expenses, consumers would have a clearer stake in the financial consequences of their choices.
Addressing the pricing distortion known as “silver loading” is another structural issue that policymakers need to consider. Restoring cost-sharing reduction payments directly to enrollees’ accounts could normalize premiums across metal tiers and reduce federal spending without reducing benefits.
Ultimately, the central challenge is not the size of the subsidies but how they work. Improving the underlying structure of the subsidy system offers a path to a more durable and affordable ACA that benefits households, insurers, and taxpayers alike. Policymakers must consider how to design the subsidy system to balance affordability, transparency, competition, and fiscal discipline for a sustainable future.

