Self-funded employer plans gain members as Marsh projects the largest cost rise since 2003

Across all employer coverage, MFA's year to June 30 shows a net loss. Net the self-funded gain against the fully insured decline and employer group enrollment fell by roughly 0.9 million people ^[18]. Over the same period the individual market lost about 4.5 million ^[19]. MFA's counts do not show where the new self-funded members came from, and the firm notes that its ASO figures are partly estimated ^[7].

The window is also short. Total US enrollment fell 2.8 percent to about 312.5 million in the 12 months to June 30, 2026, according to MFA ^[4]. Only about six months of that period fall after the subsidies lapsed ^[20]. The migration estimate was a forecast made before the lapse ^[2], and half a year of filings is too little to confirm or reject it. KFF projected a possible drop in average effectuated enrollment on the marketplace, from 22.3 million in 2025 to about 17.5 million in 2026 ^[12].

A skeptic would read those totals as saying there is no inflow to price into a renewal. In my view the national count is the wrong unit for a single employer. hcamag expects the shift to land hardest on small and mid-market employers whose workforces are largely hourly or lower-wage, and where many had passed up the employer plan for subsidized individual coverage ^[21]. An employer of that kind can see its own enrollment climb while the national employer total falls. Low layoffs already leave most employers carrying a large, stable covered population, and new enrollees add to that base ^[23].

The trade-off sits in cost-sharing, set against a cost rise of the size Marsh projects ^[3]. Only half of workers could get through a few months without income, according to Zurich Insurance Group's Global People Resilience Study 2026, which surveyed 11,175 working-age adults across 16 countries ^[13]. hcamag notes that some new enrollees will have deferred care while uninsured or on high-deductible bronze plans ^[22]. Bronze rose from 30 percent to 40 percent of marketplace selections in 2026, according to KFF ^[11]. Hold cost-sharing flat and the employer absorbs more of the increase. Raise it and the workers newest to the plan carry exposure the Zurich figures suggest many cannot absorb.

The next eligibility change is already on the calendar. Medicaid lost 4.1 million members over the same 12 months, MFA data show, reflecting the end of pandemic-era continuous enrollment and new eligibility limits under Public Law 119-21 ^[14]. hcamag describes the coming work requirement as a second wave ^[17]. If that wave reaches employer plans, it arrives under whatever terms the 2027 renewals set this quarter ^[15].