ACA Subsidies in Limbo: What the Senate Framework Means for Patients

The enhanced Affordable Care Act (ACA) premium tax credits expired on January 1, 2026, and millions of Americans are now facing the consequences. According to the Kaiser Family Foundation, subsidized enrollees are seeing their out-of-pocket premium payments increase by an average of 114%. For a single mother in social work like Katelin Provost, that means watching her monthly premium jump from $85 to nearly $750, a ninefold increase that forces an impossible choice between her own coverage and her daughter's.

This is the reality for more than 20 million Americans who benefited from the enhanced subsidies first enacted in 2021 as a COVID-19 pandemic response. The Wall Street Journal reports that roughly four in ten ACA enrollees had been paying nothing toward their premiums under the enhanced credits—more than double the share in 2020. That era ended last week, and Congress is now scrambling to respond amid growing political pressure and the specter of another government shutdown deadline on January 30.

The House Vote: Forcing the Issue

Last Thursday, the House passed a three-year extension of the enhanced subsidies, a bill that has no chance of becoming law in its current form. The Senate rejected an identical measure in December. So why hold the vote?

The answer lies in a procedural rebellion that caught House leadership off guard. Four swing-district Republicans—Reps. Mike Lawler of New York and Robert Bresnahan, Brian Fitzpatrick, and Ryan Mackenzie of Pennsylvania—signed a Democratic discharge petition to force the vote over Speaker Mike Johnson's objections. Last Wednesday, nine Republicans joined Democrats on a procedural motion to advance the bill.

These centrist Republicans are calculating political survival. As Rep. Fitzpatrick told The Hill, "Everyone's lamenting discharge petitions. There's an easy way to fix that: Put bills on the floor that have majority support. It's not hard." The vote serves a strategic purpose: it creates a legislative vehicle the Senate can amend and sends a clear signal that inaction carries electoral consequences in November's midterms.

The Senate Framework Takes Shape

While the House engages in political theater, a bipartisan Senate group led by Sens. Bernie Moreno (R-Ohio) and Susan Collins (R-Maine) has been negotiating a compromise. According to Politico, legislative text could be ready as early as today.

The emerging framework includes a two-year extension of enhanced subsidies with several Republican-demanded reforms. The Wall Street Journal outlines the key elements: an income cap excluding households earning more than 700% of the federal poverty level (approximately $225,000 for a family of four), a requirement that enrollees pay at least $5 per month toward their coverage, and $100,000 fines on insurers who sign up "phantom enrollees" without their knowledge. In the second year, enrollees would have the option to direct their subsidy funds into a pre-funded health savings account instead of having them flow to insurance companies.

The framework also reportedly includes measures to directly fund cost-sharing reductions (CSRs), which could generate significant savings. The Committee for a Responsible Federal Budget estimates that direct CSR funding would reduce deficits by over $50 billion over a decade while lowering silver plan premiums by 10% to 20%. This would end the practice of "silver loading," where insurers inflate silver plan premiums to compensate for CSR costs the federal government stopped paying in 2017.

Sen. Moreno told NPR, "We're in the red zone. But that does not mean a touchdown. It could mean a 95-yard fumble."

The Barriers to a Deal

Two sticking points threaten to derail negotiations: abortion coverage and the elimination of $0 premium plans.

On abortion, Republicans want explicit language preventing subsidies from flowing to plans that cover the procedure. Democrats counter that current law already addresses this concern—ACA plans that cover abortion must charge enrollees a separate $1 per month, segregating federal funds from abortion services. Sen. Ron Wyden (D-Ore.) warned Fox News, "I am not going to open the door to Hyde, given what happens and what has been seen historically when you do that. If you open the door, it will get drafty in a hurry."

President Trump complicated matters when he told House Republicans to be "flexible on Hyde," drawing pushback from conservatives. Sen. Moreno has since indicated the framework does not change current abortion policy, calling the issue "peripheral" to the core negotiations.

The second obstacle carries more direct implications for patient access. The proposed $5 monthly minimum premium—designed as an anti-fraud measure—would eliminate $0 premium plans that currently cover millions of low-income enrollees. Sen. Wyden called this a "rate hike" affecting 8 million people. Sen. Jeanne Shaheen (D-N.H.) noted, "Data shows that you lose a lot of people at the lowest income levels when you do that."

This concern is grounded in evidence. The NIH Clinical Guidelines on Antiretroviral Therapy are direct: "Out-of-pocket costs for people with HIV can be prohibitive, creating a barrier to the initiation and continuation of ART. Cost sharing results in higher rates of people not initiating ART, prescription abandonment at the pharmacy, decreased adherence, and more frequent drug discontinuation." The guidelines note that in 2022, the CDC's Medication Monitoring Project found that among people with HIV who had stopped taking antiretroviral therapy, 34% reported that money or insurance problems contributed to stopping treatment. For people managing chronic conditions requiring consistent care, even modest cost-sharing can disrupt treatment continuity with serious downstream consequences for both personal health and public health goals.

Why This Matters for People Living with Chronic Conditions

The evidence on cost-sharing and health outcomes should inform how we evaluate any compromise. The Commonwealth Fund's 2023 Health Care Affordability Survey found that 37% of marketplace enrollees reported delaying or skipping needed care due to cost in the prior 12 months. Among those who delayed care, 61% said a health problem got worse as a result. One-third of marketplace enrollees reported paying off medical debt.

These affordability challenges fall disproportionately on certain communities. The Center on Budget and Policy Priorities notes that 23% of Black enrollees and 18% of Hispanic enrollees in private insurance reported problems paying medical bills, compared to 15% of white enrollees.

For people living with HIV, coverage continuity directly affects health outcomes. The NIH Clinical Guidelines emphasize that "health insurance and prescription drug coverage can directly affect clinical outcomes for people with HIV; changes to coverage can result in lapses in viral suppression and should be anticipated as best possible." The guidelines specifically warn that disengagement from care occurs more frequently during transitions in coverage, including when people switch insurance plans or experience changes in employment status. With wholesale acquisition costs for commonly prescribed single-tablet antiretroviral regimens ranging from approximately $2,800 to $4,700 per month, the stakes of coverage disruption are substantial.

As CANN's December analysis detailed, New York City's 2024 HIV surveillance data showed diagnoses rising for the fourth consecutive year, with 86% of new diagnoses among Black or Latino people and 48% of those interviewed lacking health insurance. The Ryan White HIV/AIDS Program and AIDS Drug Assistance Programs (ADAPs) provide critical safety net support, but these programs work best when complementing stable insurance coverage rather than substituting for it.

The KFF analysis of proposed Medicaid cost-sharing requirements offers a window into what happens when cost barriers are introduced for vulnerable populations. Under a maximum cost-sharing scenario, Medicaid expansion enrollees with three or more chronic conditions could face average annual costs of $1,248—potentially exceeding the 5% of income cap for those at 100% of the federal poverty level.

What Comes Next

Any Senate deal requires 60 votes to overcome a filibuster, meaning at least seven Democrats must join all 53 Republicans, or significant bipartisan support must materialize. Sen. Moreno has indicated he needs 35 Republican senators on board to feel confident in the level of GOP support. Senate Majority Leader John Thune has said any deal must get a "big vote" among Republicans.

The political calendar adds pressure. The January 30 government funding deadline looms, and neither party has appetite for another shutdown after last fall's 43-day standoff. An extended open enrollment period would likely accompany any deal, giving people who dropped coverage due to premium spikes a chance to re-enroll.

For advocates, the coming days demand close attention. The specific legislative text—particularly provisions around minimum premiums, income verification, and any changes to covered services—will determine whether a compromise actually improves access or introduces new barriers. Contact your Senators to emphasize that affordability must remain central to any reform. Monitor for the final text expected early next week. And prepare to help community members navigate an extended enrollment period if one materializes.

The enhanced subsidies enabled record ACA enrollment of 25.2 million in early 2025, according to KFF data. What happens in Congress over the next two weeks will determine whether that progress holds or unravels, and whether the people who depend on affordable coverage can continue accessing the care they need.

Federal Policy Changes Threaten to Overwhelm ADAPs

Established in 1987, AIDS Drug Assistance Programs (ADAPs) were the first federally supported initiative to help states purchase AZT (zidovudine), then the only approved antiretroviral drug available for people living with HIV (PLWH). When Congress enacted the Ryan White Comprehensive AIDS Resources Emergency (CARE) Act in 1990, ADAPs were formally incorporated into what would become the Ryan White HIV/AIDS Program. Nearly forty years later, these programs remain the backbone of HIV treatment access in the United States, supporting medication coverage for those without affordable insurance options and sustaining the nation’s viral suppression gains.

That foundation is now under strain. A series of converging federal policy changes threatens to unravel the safety net that ensures continued access to lifesaving HIV treatment.

The One Big Beautiful Bill Act, enacted July 4, 2025, combined with the expiration of enhanced ACA Premium Tax Credits on December 31, 2025, and proposed federal funding reductions for Fiscal Year 2026, have created what NASTAD describes as "an unprecedented fiscal storm." The Congressional Budget Office estimates that H.R. 1, combined with the end of enhanced Premium Tax Credits, will leave 14.2 million more Americans uninsured by 2034. Another 750,000 to 1.8 million Marketplace enrollees are projected to lose coverage under the 2025 Marketplace Integrity Rule.

For ADAPs, the timing could not be worse. NASTAD data show ADAP enrollment increased 8 percent between 2019 and 2023, with new enrollment rising 28 percent and prescription drug expenditures up 10 percent. Program administrators are already managing cost growth, changing insurance landscapes, and expanding client need. The convergence of these federal shifts represents not a single budget gap, but a cumulative structural failure that could overwhelm the system responsible for sustaining treatment access for more than 270,000 people nationwide.

When the Safety Net Last Failed

The last major ADAP funding crisis, in 2010 and 2011, offers a clear warning. During that period, national ADAP waitlists grew from 2,937 to 9,217 people within twelve months, even after an emergency $25 million federal allocation. The consequences were immediate and measurable. Three deaths in South Carolina among people waiting for medication became a national call to action. Congress responded by reprogramming Ryan White funding and authorizing additional emergency allocations between 2010 and 2013, and waitlists were fully eliminated by 2017.

The difference today is scale and complexity. The current threat is not a temporary funding shortfall but a sequence of federal policy changes that simultaneously reduce insurance coverage, restrict Medicaid access, and diminish the resources available to offset those losses. Each component amplifies the pressure on ADAPs, narrowing every available safety valve.

The lessons from 2010 remain relevant. When the safety net fails, the consequences are measured not in spreadsheets but in treatment interruptions, declining viral suppression rates, and preventable deaths. Without urgent federal and state intervention, ADAPs face conditions that could produce a repeat of that crisis, magnified by broader systemic strain and political indifference.

Medicaid Work Requirements: Paperwork as Policy Weapon

H.R. 1 introduces the largest reduction to Medicaid in U.S. history, with nearly $1 trillion in cuts projected from 2025 through 2034. Beginning January 1, 2027, most Medicaid expansion adults will be required to document at least 80 hours of “qualifying activities” each month to maintain coverage. The Congressional Budget Office estimates that these provisions will result in 4.8 million more people losing coverage by 2034.

Research shows that two out of three enrollees who lose Medicaid under work requirement policies are already employed or qualify for exemptions. The result is not an increase in employment but a rise in administrative loss of coverage.

Arkansas’s 2018 work requirement experiment illustrates what lies ahead. More than 18,000 people lost coveragewithin months, primarily due to confusion and difficulties with the state’s online reporting system. Employment rates did not increase.

Nationally, about 10 percent of Medicaid renewals currently result in “procedural disenrollment,” meaning people lose coverage for paperwork reasons despite remaining eligible. H.R. 1 worsens this by requiring Medicaid enrollees to renew eligibility every six months instead of annually, doubling the opportunities for administrative failure.

For people living with HIV, Medicaid is a primary source of healthcare coverage. Nationally, approximately 40 percent of people receiving HIV care are enrolled in Medicaid. These provisions directly threaten treatment continuity by increasing administrative barriers and coverage interruptions. The legislation also reduces retroactive eligibility from three months to one or two months, raising costs for ADAPs that depend on retroactive reimbursement for medications dispensed while coverage applications are pending.

The Marketplace Affordability Cliff

The expiration of enhanced ACA Premium Tax Credits will create an affordability crisis for people living with HIV who earn too much to qualify for Ryan White services but depend on subsidized marketplace plans. KFF estimates that marketplace enrollees will see average premium payments more than double in 2026, increasing by 114 percent from $888 annually to $1,904. Approximately 1.5 million people earning above 400 percent of the federal poverty level will lose all subsidies entirely.

A larger share of people living with HIV receive marketplace coverage than the general population. For a 45-year-old in Miami-Dade County earning $38,000, annual premiums would rise by $1,699, from $117 to $259 per month. Given that antiretroviral therapy typically costs $36,000 to $48,000 annually and total healthcare expenses average $30,000, marketplace affordability is critical to maintaining viral suppression.

Insurers are building in additional premium increases of roughly four percent in anticipation of the subsidy expiration, assuming healthier enrollees will drop coverage and leave behind a sicker risk pool. Average Healthcare.gov plan premiums are projected to rise 26 percent for 2026. The Congressional Budget Office projects that the uninsured population will grow by 2.2 million people in 2026 alone without an extension of the tax credits, eventually reaching 4.2 million.

Federal Funding Cuts Compound the Crisis

While coverage losses increase, federal budget proposals for FY2026 would eliminate the very programs that support ADAPs and coordinated HIV care. The White House budget proposes a $74 million reduction to the Ryan White HIV/AIDS Program, lowering total funding to $2.5 billion by eliminating Part F programs that include the AIDS Education and Training Centers, dental programs, and Special Projects of National Significance.

The House Appropriations Committee proposes deeper reductions, eliminating $525 million in Ryan White funding, or roughly 20 percent of the program’s total. These cuts would affect more than 400 HIV clinics that provide medication, case management, and medical care nationwide.

The House proposal also eliminates the entire $1 billion budget for CDC HIV prevention, including $220 million for the Ending the HIV Epidemic initiative. The HIV+Hepatitis Policy Institute describes this as “not a bill for making America healthy again, but a disastrous bill that will reignite HIV in the United States.” The Foundation for AIDS Research projects that ending prevention funding alone could lead to 144,000 new HIV diagnoses, 15,000 deaths, and $60.3 billion in healthcare costs by 2030.

The Senate Appropriations Committee rejected these reductions by a bipartisan vote of 26–3, maintaining existing levels for domestic HIV prevention programs. This outcome offers temporary stability, but reconciliation between House and Senate versions remains uncertain.

Immediate Actions Required

The NASTAD analysis warns that the convergence of federal coverage losses and funding reductions could force ADAPs into crisis conditions reminiscent of 2010. While states can employ fiscal management strategies to delay the impact, the core solutions lie in federal policy.

Congress must extend enhanced Premium Tax Credits through at least 2027 to stabilize the individual marketplace and prevent subsidy loss for people living with HIV who rely on private coverage. Lawmakers should reject proposed eliminations of Ryan White Part F and CDC HIV prevention funding, which have produced measurable long-term savings by reducing new infections and sustaining treatment continuity. Maintaining these investments is far less costly than responding to the resurgence of uncontrolled HIV transmission.

States also play a central role. Strengthening coordination between Ryan White programs, ADAPs, and marketplace enrollment systems, as demonstrated in California and New York, can mitigate insurance disruptions and preserve treatment adherence during policy transitions.

NASTAD emphasizes that continuity of care must remain the guiding principle throughout any period of programmatic change. Ensuring uninterrupted access to medication, case management, and communication between providers and clients is critical to maintaining public trust and preventing viral rebound.

The intersection of these federal policies represents a defining test for HIV care in the United States. The ADAP crisis of 2010 showed that delay has a human cost measured in treatment lapses and preventable deaths. Policymakers again face a choice between sustaining a proven safety net or repeating the mistakes that history has already documented.

September Shutdown Could Cripple Open Enrollment as HIV Patients Face Coverage Crisis

Congress faces a September 30th government funding deadline that could shut down federal agencies just as Americans prepare to experience unprecedented healthcare premium increases during the November open enrollment period. The seven-week stopgap funding bill released by House Republicans would only extend government operations through November 21st, creating the possibility of multiple shutdowns right as people living with HIV and millions of others discover that their healthcare costs will increase dramatically for 2026.

The timing creates a perfect storm of healthcare disruption. Enhanced ACA subsidies expire December 31, 2025, but insurers have already built the expected 75% premium increases into their 2026 rates. When open enrollment begins November 1, Americans shopping for coverage will immediately see these massive premium spikes, creating intense political pressure on Congress just as government funding battles reach their peak.

For people living with HIV who rely on ACA marketplace plans, this convergence threatens treatment continuity at the worst possible moment. Many earn too much to qualify for Ryan White HIV/AIDS Program services but depend on enhanced subsidies to make coverage affordable. The prospect of 75% premium increases forces impossible choices between maintaining viral suppression and financial stability.

Premium Sticker Shock Meets Shutdown-Threatened Infrastructure

Insurers nationwide have proposed a median premium increase of 18% for 2026, more than double last year's 7% median increase. The majority explicitly cite the expected expiration of enhanced premium tax credits as driving rates an additional 4 percentage points higher than they would otherwise charge.

Average out-of-pocket premium payments will increase by more than 75% when enhanced subsidies expire, translating to roughly $700 more annually for the typical family. People earning between 100% and 150% of the federal poverty level would see their average premiums rise from $0 to $387 per year. In Maryland, carriers requested 17.1% increases, but rates would drop to 7.9% if Congress extends enhanced subsidies, illustrating the immediate financial impact of political inaction.

These massive increases hit Americans during November open enrollment while government infrastructure faces shutdown disruption. The September 30 deadline threatens systems needed for November 1 enrollment, and even the Republican stopgap bill expires November 21 during the critical enrollment period.

Healthcare.gov and state marketplaces require functioning federal systems to process applications and verify income for subsidy eligibility. Historical shutdown impacts show services degrade rapidly during funding lapses. The timing compounds administrative challenges from the Trump administration's Marketplace Integrity and Affordability Rule, requiring people in $0 premium plans to verify eligibility or face minimum $5 monthly charges starting in 2026.

Insurers cannot adjust these rates after open enrollment begins. Blue Cross Blue Shield of Vermont warns that healthier members will leave at a disproportionately higher rate than those with significant healthcare needs, worsening the risk pool. This death spiral dynamic makes immediate Congressional action an absolute necessity, both politically and practically, as Americans navigate premium increases while government systems fail to function.

Political Standoff Intensifies as Healthcare Costs Hit Constituents

Traditional shutdown politics change fundamentally when constituents experience immediate healthcare cost increases during an election cycle. Senate Minority Leader Chuck Schumer argues Democrats hold a stronger position because Republicans face blame for both the shutdown and healthcare cost increases their policies created.

House Speaker Mike Johnson insists ACA subsidy negotiations belong in December when they expire, calling them "a December policy debate and decision, not a September funding matter." This ignores the practical reality that Americans need certainty when making coverage decisions during November open enrollment. Families cannot wait until December to learn whether their January 2026 premiums will be affordable.

The electoral pressure becomes intense when 22 million Americans face premium increases. TD Cowen's analysis notes that "many Congressional Republicans are also eager to extend these subsidies for fear of health insurance sticker shock in advance of the November 2026 midterms." Only Senator John Fetterman has indicated willingness to vote for Republican funding without healthcare provisions, suggesting Democrats maintain unity while Republicans need Democratic cooperation they have refused to seek.

The Trump Administration compounds uncertainty through potential "pocket rescissions" that could cancel federal funding without Congressional approval. Budget Director Russell Vought defended this controversial tactic, noting "the money evaporates at the end of the fiscal year." This raises constitutional questions about Congressional spending authority and creates a trust crisis for Democrats who fear GOP leaders could agree to healthcare provisions in negotiations only to have the Administration cancel funding through rescissions after a continuing resolution passes. Lawmakers must consider both immediate shutdown impacts and the Administration's demonstrated willingness to bypass Congress on funding decisions.

State and Local Healthcare Programs Face Immediate Funding Disruption

Government shutdowns immediately disrupt state and local healthcare programs through suspended grant payments and federal workforce reductions. During shutdowns, 45% of HHS staff are furloughed, including personnel who process grants to state health departments and community organizations providing HIV services. The 2013 shutdown left 477 grant payment requests totaling $165 million unpaid while programs continued operating on dwindling reserves.

State health departments must issue stop work orders to community organizations when Ryan White grant payments cease during shutdowns. State AIDS Drug Assistance Programs face immediate medication supply crises as federal funding stops flowing to programs serving 265,000 low-income Americans with HIV medications. Unlike programs with multi-year appropriations, these discretionary programs lose payment authority immediately when government shuts down.

Community health centers serving 32.5 million Americans operate on margins where federal grants constitute 11-18% of revenue. Recent funding disruptions provide a preview of shutdown impacts: Virginia's 16 of 31 federally qualified health centers lost federal funding access, forcing three Richmond facilities to close entirely. Centers typically maintain 100 days to six months of reserves, making extended shutdowns particularly devastating.

The Women, Infants, and Children program loses funding within days of shutdown, cutting services to 6.3 million participants including 39% of all U.S. infants. State health departments lack reserves to float these federal programs, forcing immediate service reductions that disproportionately impact communities already facing healthcare access barriers.

Healthcare Access Cannot Wait for Political Theater

People living with HIV and other chronic conditions cannot afford treatment interruptions while Congress debates funding priorities. Those caught between Ryan White eligibility limits and unaffordable marketplace premiums face a healthcare access crisis manufactured by political inaction.

Healthcare advocates must demand that any continuing resolution include immediate extension of enhanced ACA subsidies through 2026. Congressional Republicans who claim to support these subsidies must prove their commitment by including them in September funding legislation, not promising future action that may never materialize.

State and local health officials should prepare contingency plans for potential grant payment disruptions while advocating with their Congressional delegations about immediate shutdown impacts on essential services. Community health centers and organizations serving people living with HIV need to communicate directly with patients about potential service disruptions and alternative care options.

Congress must choose between responsible governance that prioritizes patient care or political theater that forces impossible choices between treatment adherence and financial survival. For people living with HIV and millions of others depending on stable healthcare access, the time for action could not be shorter.

Enhanced Premium Tax Credits Face Political Crossroads as Coverage Crisis Looms

The enhanced premium tax credits that have made Affordable Care Act (ACA) marketplace coverage affordable for millions of Americans face an uncertain future as political divisions within the Republican Party intensify. With these subsidies set to expire on December 31, 2025, and insurers proposing median premium increases of 15% for 2026—the steepest in over five years—people living with HIV (PLWH) and other chronic conditions find themselves caught in a manufactured crisis that threatens to undermine decades of progress toward treatment accessibility.

The stakes extend far beyond healthcare economics. For middle-income people living with HIV who earn too much to qualify for Ryan White services but depend on subsidized marketplace coverage, the convergence of expiring tax credits and soaring premiums represents a direct threat to viral suppression and community-wide prevention efforts. As Republican leaders grapple with internal divisions over extending these pandemic-era benefits, the August 2025 deadline for insurers to finalize rates creates an urgent timeline for Congressional action.

Market Instability Signals Deeper Systemic Problems

ACA marketplace insurers across 19 states and the District of Columbia are requesting their largest premium increases since 2018, with 105 insurers proposing a median 15% increase—more than double the 7% median increase for 2025. These proposals reflect multiple interconnected pressures that disproportionately impact people managing chronic conditions requiring continuous care.

The distribution of proposed increases reveals the severity of market instability. While 32 insurers are requesting increases between 10-15%, another 24 are seeking 15-20% increases, and 20 insurers want increases exceeding 20%. Critically, no insurers have requested rate decreases for 2026, signaling unanimous expectations of higher costs across the marketplace.

State-by-state variations compound these challenges. Colorado leads with a 28.4% average increase, with insurers attributing at least 8% specifically to uncertainty surrounding enhanced premium tax credit expiration. Arkansas follows at 26.2%, Tennessee at 24.2%, and Illinois at 23.4%. These increases reflect not just underlying healthcare cost inflation running at 8% annually, but also insurers' strategic responses to anticipated market disruption.

Insurers are building approximately 4% additional premium increases specifically to cover the expected impact of enhanced tax credit expiration. This reflects their anticipation that healthier enrollees will abandon the marketplace due to unaffordability, leaving behind a sicker, more expensive risk pool that necessitates even higher premiums in subsequent years.

The 75% Premium Shock Threatens Treatment Continuity

The expiration of enhanced premium tax credits will cause out-of-pocket premiums to increase by over 75% for the 93% of marketplace enrollees who currently receive subsidies. For people living with HIV, this creates an acute crisis given the intersection of their income levels, geographic distribution, and healthcare needs.

The enhanced credits currently save the average marketplace enrollee $705 annually, representing a 44% reduction in premium costs. However, their most significant impact has been eliminating the "subsidy cliff" that previously cut off all assistance at 400% of the federal poverty level. The 1.5 million people currently enrolled above this threshold would lose all subsidies entirely, reverting to full premium payments that many cannot afford.

For a 45-year-old person living with HIV earning $65,000 annually—just above many states' Ryan White eligibility limits—annual premiums would jump from $5,525 to $6,466, an increase of $941. For older enrollees, the impact becomes even more severe, with a 60-year-old couple earning $82,000 seeing monthly premiums skyrocket from $581 to $2,111, representing an annual increase of $18,400.

Geographic disparities compound these challenges. Wyoming enrollees would see 195% premium increases averaging $1,872 annually, while rural premiums already run 10% higher than urban areas. For people living with HIV, who are disproportionately concentrated in the South where many states haven't expanded Medicaid, these geographic disparities create additional barriers to affordable coverage.

HIV Care Economics Underscore Coverage Urgency

The unique healthcare needs of people living with HIV underscore why affordable insurance coverage remains essential for the community. Annual HIV medication costs range from $36,000 to $48,000 for standard antiretroviral therapy regimens, with complete annual healthcare expenses averaging $30,000 per person. These medications account for 60% of total HIV care costs, creating an unforgiving financial equation for those facing coverage loss.

Research demonstrates a direct, quantifiable relationship between insurance affordability and health outcomes critical for people living with HIV. Each $1,000 increase in out-of-pocket costs correlates with decreased medication adherence, while those with continuous insurance coverage show 3.2 times higher antiretroviral adherence rates compared to the uninsured. This relationship directly impacts viral suppression, which prevents both disease progression and transmission to others.

Current insurance patterns reveal the precarious coverage situation for many people living with HIV. While 40% rely on Medicaid and 35% have private insurance, 11% remain uninsured. Geographic disparities compound the challenge—52% of new HIV diagnoses occur in the South, where many states haven't expanded Medicaid and marketplace premiums run highest.

Republican Division Creates Policy Uncertainty

Republican leaders face growing internal pressure to extend enhanced premium tax credits as Trump's pollster warns that the GOP will pay a "political penalty" in the 2026 election if the funding expires. The warning carries particular weight given that 56% of ACA enrollees live in Republican congressional districts, making coverage losses a direct threat to GOP electoral prospects.

The political dynamics reveal significant fractures within the party. Rep. Brian Fitzpatrick (R-Pa.), representing a swing district, advocates for continuing the credits to avoid price increases, while Sen. Mike Rounds (R-S.D.) supports extension despite representing a deep-red state. Even Sen. Tommy Tuberville (R-Ala.), running for governor, calls on his party to consider an extension, though he expresses concern about costs.

However, conservative opposition remains fierce. Rep. Andy Harris (R-Md.), chair of the House Freedom Caucus, wants the funding to end, calling it unaffordable Covid-era policy. Rep. Chip Roy (R-Texas) dismisses extension efforts as a "nonstarter," while Sen. Ron Johnson (R-Wis.) flatly opposes preserving the subsidies.

The $335 billion ten-year cost of permanent extension creates a significant hurdle for fiscally conservative Republicans. Sen. Thom Tillis (R-N.C.), an early proponent of continuing the funds, suggests modifications may be necessary "to get Republicans on board," while House Speaker Mike Johnson (R-La.) keeps options open, saying the issue is "on the radar" but hasn't come up yet.

Ryan White Program Cannot Fill Coverage Gap

The Ryan White HIV/AIDS Program, designed as a safety net for low-income people living with HIV, typically limits eligibility to those earning 400-500% of the federal poverty level, varying by state. This creates a critical coverage gap for middle-income people who earn too much for Ryan White services but cannot afford unsubsidized marketplace premiums.

The enhanced premium tax credits have successfully bridged this gap for an estimated 50,000 Ryan White clients who received marketplace premium assistance by 2014, a number that has grown significantly since. These people typically fall in the 150-400% federal poverty level range, using Ryan White for premium assistance, copay help, and wraparound services while relying on ACA plans for comprehensive coverage beyond HIV-specific care.

The program's "payer of last resort" status means it cannot serve as primary insurance, making affordable marketplace coverage essential for non-HIV medical needs. Without marketplace coverage, Ryan White programs alone cannot provide comprehensive healthcare access for people living with HIV.

Policies for Sustainable Solutions

The convergence of enhanced tax credit expiration and massive premium increases demands immediate Congressional action to prevent a preventable public health crisis. Policymakers must recognize that insurance affordability directly impacts HIV treatment adherence and viral suppression—factors that prevent transmission and save lives.

Congress should extend enhanced premium tax credits through at least 2027 to provide market stability while developing longer-term reforms. This extension must maintain the elimination of the subsidy cliff at 400% of federal poverty level, ensuring continued coverage for middle-income people living with HIV who fall outside Ryan White eligibility.

State policymakers should strengthen coordination between Ryan White programs and marketplace enrollment, following successful models in California and New York. This includes streamlining enrollment processes, improving data sharing between programs, and ensuring comprehensive support for people transitioning between coverage sources.

The Urgency of Action

As insurers face their August 2025 deadline to finalize rates based on uncertain Congressional action, the window for preventing coverage catastrophe narrows rapidly. Congressional Budget Office projections show marketplace enrollment dropping from 22.8 million to 18.9 million in 2026 alone, with continued declines to 15.4 million by 2030 if enhanced credits expire.

For people living with HIV who have achieved viral suppression through consistent treatment access, January 1, 2026 represents a politically manufactured crisis that threatens both individual health outcomes and community-wide prevention efforts built on treatment as prevention. The precision of this policy failure specifically targets middle-income Americans who work, pay taxes, and contribute to their communities, yet find themselves earning just enough to be abandoned by both safety net programs and affordable insurance markets.

The stakes transcend healthcare policy, touching fundamental questions about American commitments to public health, health equity, and the value we place on treatment accessibility. With Republican polling data showing broad support for continuing these credits and electoral consequences looming in competitive districts, the political incentives align with public health imperatives. Whether Congressional Republicans recognize this convergence and act accordingly will determine whether decades of progress toward HIV treatment accessibility survives the current political moment.