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The Trump Administration has reportedly eliminated nearly 3 million fraudulent Affordable Care Act Marketplace enrollments, according to a report from the US Department of Health and Human Services (HHS). However, the department estimates that around 2.6 million “improper or phantom enrollments” still remain on the Marketplace. The report suggests that changes made to the ACA since 2021 to increase accessibility, including reduced verification requirements and extended enrollment periods, may have incentivised insurance brokers to fraudulently enroll people into $0-premium plans.
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A New Report Reveals High Levels of Fraud in ACA Marketplace Enrollments
The U.S. Department of Health and Human Services (HHS) has released a report suggesting that nearly 3 million fraudulent enrollments in the Affordable Care Act (ACA) Marketplace have been eradicated by the Trump Administration. However, it’s estimated that approximately 2.6 million “improper or phantom enrollments” still exist.
Fraud in ACA Marketplaces Since 2021
The research, conducted by the HHS Assistant Secretary for Planning and Evaluation (ASPE), argues that fraudulent activity in the ACA Marketplaces has surged following the 2021 passage of the American Rescue Plan. The legislation introduced flexibility in the marketplace, particularly for individuals earning between 100-150% of the federal poverty level. It offered year-round enrollment and reduced verification requirements for those eligible for $0-premium plans—features later extended by the 2024 Inflation Reduction Act.
Did Marketplace Flexibility Lead to Fraud?
While some health experts argue that these changes have enhanced accessibility to affordable health insurance, ASPE’s data suggests the enrollment increases might be fraudulent. The argument is that insurance brokers and agents, who earn commission for enrollments, may have been incentivized to enroll individuals onto $0-premium plans without proper verification.
Rising Enrollment in $0-Premium Plans
ASPE found that 7.6 million more people enrolled in a $0-premium plan after the policies of the American Rescue Plan and the Inflation Reduction Act were implemented. This increase coincided with a spike in enrollees who filed zero claims, indicating no use of healthcare services. Though ASPE recognizes that lower usage rates are typical for low-income individuals, the data from 2024 to 2026 suggests an abnormal pattern.
“This may signal an uptick in fraudulent or improper enrollment by agents and brokers leveraging the fact that the poorest enrollees are not required to pay a premium, and therefore receive no bill and can be enrolled without their knowledge,” the ASPE report reads.
Estimates of Fraudulent Enrollments
According to ASPE, in 2025, a staggering estimate of 5.6 million enrollments in the ACA Marketplace was deemed fraudulent or phantom.
Efforts to Combat Fraud
ASPE argues that the Trump Administration’s Marketplace Integrity and Affordability Rule has been instrumental in combating this problem. Introduced in 2025, this rule aimed to “ensure those receiving subsidies were actually eligible for those subsidies” by enforcing stricter eligibility, enrollment, and enforcement standards.
As a result, 2.9 million fraudulent or phantom enrollments were purged from the ACA Marketplaces—1.5 million enrollees were found undeserving of the subsidies they were receiving, and the coverage for 1.4 million enrollees was terminated or blocked through February 2026. Despite these efforts, approximately 2.6 million improper or phantom enrollments, including over 1 million enrollments without a social security number, remain, according to the report.
Declining ACA Marketplace Enrollment
At the same time, public health officials have noticed a declining trend in overall ACA Marketplace enrollment, which they attribute to the expiration of enhanced premium tax credits and overall affordability challenges. As of January 2026, Marketplace enrollment had fallen from 23.6 million signups to 22.8 million, according to CMS.
While the Trump administration ties this decline to increased fraud enforcement, some critics argue that legitimate enrollees may be adversely affected. “While the Trump administration attributes this drop in enrollment to their attempts to address fraud, this coverage loss happened at the same time millions of people faced steep increases in their premium payments — often in the double or even triple digits — with the expiration of enhanced tax credits,” comments Cynthia Cox, senior vice president and director of the Program on the ACA at KFF, in a blog post.
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