Paragon Study Says 6.2 Million ACA Enrollees Were Improper and Up to $25 Billion in Subsidies Could Be At Risk

Overview

• This week Paragon Health Institute released a study estimating about 6.2 million exchange sign-ups were improper in 2026 and that improper subsidies could total as much as $25 billion.
• The findings build on prior government warnings: CMS has estimated as many as 4.4 million improper 2024 enrollments, and the GAO showed the enrollment system can be used to obtain subsidies for fake people.
• Paragon says improper sign-ups are concentrated on the federal HealthCare.gov platform and in states that did not expand Medicaid, with many enrollees claiming the lowest income bracket that qualifies for the biggest subsidies.
• The administration has already tightened rules, including a May CMS marketplace overhaul, efforts to remove duplicate Medicaid/exchange enrollments, and a White House fraud task force targeting brokers and verification failures.
• If the reported improper sign-ups are removed, taxpayers could save billions but effectuated enrollment may fall, which could reduce access to care and shift costs to hospitals and state programs.