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Obamacare Enrollment Fraud

Due to a combination of expensive subsidies, lax verification procedures, and perverse incentives among enrollees, brokers and insurers to misstate enrollee income, rampant improper enrollment and fraudulent expenditures characterized the ACA exchanges during the Biden administration. A Paragon report estimated there were four to five million improper enrollees in fully-subsidized plans in 2024, with an estimated cost to taxpayers of between $15-$26 billion. Paragon’s estimates were validated by the Department of Health and Human Services in a March 2025 proposed rule, aimed largely at reducing improper enrollment.

Obamacare Enrollment Fraud

Due to a combination of expensive subsidies, lax verification procedures, and perverse incentives among enrollees, brokers and insurers to misstate enrollee income, rampant improper enrollment and fraudulent expenditures characterized the ACA exchanges during the Biden administration. A Paragon report estimated there were four to five million improper enrollees in fully-subsidized plans in 2024, with an estimated cost to taxpayers of between $15-$26 billion. Paragon’s estimates were validated by the Department of Health and Human Services in a March 2025 proposed rule, aimed largely at reducing improper enrollment.

Key Research

Paragon Pics

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Coverage of The Great Obamacare Enrollment Fraud

The Journal penned a July 12 editorial entitled, The Rising Costs of the Non-Affordable Care Act. Based on updated CBO estimates, the cost of the ACA’s coverage provisions will be $2.7 trillion over the next decade. And that assumes that the enhanced Obamacare subsidies to health insurers expire after 2025 as they are slated to do and as we strongly recommend happen. Extending them would cost another $400 billion and create a host of other problems, including more small employers dropping coverage. The Journal referenced Paragon’s report and our findings on how rampant fraud is one reason why costs have increased:

The Administration also revised regulations that eliminated multiple-income verification requirements, making it easier for people to qualify for subsidies. According to a new paper by Paragon Health Institute, millions of enrollees misreport their incomes and receive more subsidies than they should.

The number claiming income between 100% and 150% of the federal poverty line—those who are eligible for subsidies that fully cover premiums and most cost-sharing—exceed the number of potential enrollees in nine states. Paragon Health estimates the cost of the fraudulent enrollment at between $15 billion and $20 billion this year alone. Ouch.

The Paragon Pic below shows those nine states and the percentage of sign-ups who report income between 100 percent and 150 percent of FPL compared to the number of people we estimate are eligible for exchange plans in that income category.

A New York Post editorial also cited The Great Obamacare Enrollment Fraud as well as the letters by the Chairs of three powerful U.S. House Committees—Energy and Commerce, Ways and Means, and the Judiciary—to government watchdog agencies to open an investigation into the fraud and causes of it. The New York Post editorial concludes:

Paragon’s researchers offer several recommendations to curb the “waste, fraud and abuse” — such as reversing Biden policies that enable “widespread fraudulent enrollment, particularly the “continuous open-enrollment period for people” claiming income below the threshold.

Yet none of its suggestion are as important as allowing the Biden-era “enhanced subsidies” to simply expire next year. These subsidies already total nearly $40 billion a year — part of $2 trillion in annual federal outlays for health care.

And they’re clearly an invitation for fraud.

Senator Grassley, one of Congress’s most aggressive conductors of oversight, has also taken notice of Paragon’s findings, citing our work in a letter to HHS Secretary Becerra and Chiquita Brooks-LaSure, the administrator of the Centers for Medicare and Medicaid Services (CMS). In two weeks, Paragon will be releasing a follow-up report that provides more detail on the perpetuation of the fraud.

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Fraudulent Exchange Enrollment Much More Severe in Non-Medicaid Expansion States and States Using HealthCare.gov

A recent Paragon report finds that there are large incentives for enrollees to misestimate income to claim more subsidy than the legal amount to which they are entitled. This problem is exacerbated by legislation signed by President Biden which made health insurance plans “free,” or fully taxpayer-subsidized, for enrollees claiming income between 100 and 150 percent of the federal poverty level (FPL). We estimate that there are roughly 5 million people enrolled illegitimately and that the cost to taxpayers will likely be $20 billion in 2024.

One of our key findings, shown in the summary table below, is that this problem is most severe in non-expansion states and states that use HealthCare.gov, the federal exchange.

As expected, the number of people misestimating their income is much greater in non-expansion states, as there is both an incentive for people above 200 percent FPL to report lower income (which also exists in expansion states) and an incentive for people with income below 100 percent FPL to report higher income.

More surprising is that fraud is much greater in HealthCare.gov states. In states that used HealthCare.gov, 8.7 million sign-ups reported enrollment between 100 percent and 150 percent FPL compared to only 5.1 million people likely eligible for such coverage, or 1.7 sign-ups for every eligible person.

Unique deficiencies with HealthCare.gov are shown when controlling for whether states expanded Medicaid. All states with state-based exchanges did expand Medicaid, but many expansion states also used HealthCare.gov. The percentage of open enrollment sign-ups reporting income between 100 percent and 150 percent FPL relative to all those ages 19-64 eligible for such coverage is more than twice as high in expansion states with HealthCare.gov than in expansion states with state-based exchanges.

Some of these problems are innocent mistakes or projection errors, but since this issue is so large, especially in states that use HealthCare.gov, there are clearly deeper problems. As discussed in the paper, there are large financial gains for insurers and brokers when enrollees misestimate their income as between 100 and 150 percent FPL. And the Biden administration has prioritized enrollment over program integrity.

Issue Experts

Brian Blase
President at Paragon Health Institute

Brian Blase, Ph.D., is the President of Paragon Health Institute. Brian was Special Assistant to the President for Economic Policy at the White House’s National Economic Council (NEC) from 2017-2019, where he coordinated the development and execution of numerous health policies and advised the President, NEC director, and senior officials. After leaving the White House, Brian founded Blase Policy Strategies and served as its CEO.

ELLE KALISZ HEADSHOT SMALLER 186A6472 V2
Program Manager

Gabrielle “Elle” Kalisz is the Program Manager at Paragon Health Institute. Gabrielle has worked in federal health policy for over five years, advancing free-market principles and partnerships.

Related Glossary Terms

ACA
ACA is an acronym for the “Affordable Care Act.” Additional Resources CBO’s New Numbers: What You Need to Know About Medicaid and Obamacare The Shortcomings of the ACA Exchanges
Exchange
An exchange is an online marketplace where people obtain Affordable Care Act (ACA) health insurance plans. Exchanges allow for the review of locally available ACA health plans, determination of tax credits, and enrollment. Exchanges may be administered by the federal government or state governments. The federal exchange is named Healthcare.gov. State exchanges are known as SBMs (state-based marketplaces) or state-based exchanges.  The four main categories of ACA health plans sold on an exchange are bronze plans, silver plans, gold plans, and platinum plans. There is also a catastrophic coverage plan that is restricted primarily to people under the age of…
Health & Human Services
HHS is the acronym for the U.S. government’s “Department of Health & Human Services.” The department oversees numerous health and welfare programs. Its strategic goals include achieving equitable access to health care, improving health outcomes both nationally and internationally, and promoting social well-being. HHS has an annual budget that exceeds one trillion dollars and the largest portion of this goes to the Centers for Medicare & Medicaid Services. The secretary appointed to lead the department must be approved by the Senate and, after approval, reports directly to the President of the United States. Prior to the change to its current…
Open Enrollment Period
An Open Enrollment Period is a predetermined time each year when eligible people may enroll in a health plan. Outside this period, a person may not enroll in the health plan except in situations where he or she qualifies for a Special Enrollment Period. An Open Enrollment Period is used to mitigate the risk of people waiting until they are sick before enrolling in a health plan. With an open enrollment period, people who do not enroll in a plan and get sick are responsible for their own medical expenses until they can secure coverage through the next enrollment period.…

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