As the debate on the Hill over the fate of the Affordable Care Act's premium tax credits rages on, a new report highlights the potential fraud risk tied to the subsidies.
The Government Accountability Office (GAO) released a report this week where its researchers attempted to sign up for the subsidies using fictitious profiles in plan years 2024 and 2025. Most of these fake applications were approved by the government, according to the report.
In 2024, the GAO submitted four applications for subsidized coverage, all of which were approved. The Centers for Medicare & Medicaid Services (CMS) paid out approximately $2,350 per month in enhanced premium tax credits for November and December.
In some cases, the analysts were asked to provide Social Security numbers, income and citizenship status to support their applications. And, though they did not do so, the applications were still approved, according to the report.
For 2025, the GAO submitted 20 applications, including the resubmission of the four identities used in 2024. Eighteen of those profiles were covered as of September 2025, according to the report, with tax credit payouts totaling $10,000 per month.
The GAO said the submissions included applications sent directly through HealthCare.gov and applications submitted with the assistance of a broker or agent. The organization acted as any consumer would during the process, including shifting digital applications to phone interactions when prompted, according to the report.
The agency said it has previously warned that there is a notable fraud risk related to the advanced tax credits, and also notes that there have been thousands of complaints submitted to the CMS from individuals who found they were enrolled in a plan or had their coverage changed without their consent.
The analysis found that misused Social Security numbers is a notable source of the fraud risk to monitor. The GAO found that more than 29,000 numbers in 2023 and 68,000 numbers in 2024 were used to receive more than a single year's worth of coverage, including the tax credits.
"CMS officials explained that the federal Marketplace does not prohibit multiple enrollments per SSN to help ensure that the actual SSN-holder can enroll in insurance coverage in cases of identity theft or data entry errors," the GAO wrote.
The agency also identified at least 30,000 applications submitted in plan year 2023 and at least 160,000 applications for 2024 that likely included changes made by brokers or agents that were not authorized.
The GAO did warn, though, that the results are not necessarily applicable to the entire population of the exchange market.
"The results, while illustrative, cannot be generalized to the full enrollment population," they wrote.
The GAO said the results suggest the CMS' fraud management protocols around the tax credits are dated and do not reflect the current state of the program. The agency established its fraud risk assessment in 2018, before the enhanced premium tax credits were implemented, and it has not been updated since.
The CMS also did not use that 2018 assessment to build an antifraud strategy, according to the report.
"Together, these weaknesses appear to hinder CMS’s ability to effectively and proactively manage fraud risks in APTC," the GAO wrote.
The report comes at a time when lawmakers in Congress are debating the future of the enhanced tax credits, which were instituted as part of the response to COVID-19 and are set to expire at the end of this year. The subsidies have driven record highs in enrollment on the exchanges, and, now, many enrollees are facing steep premium increases for 2026 should they renew.
Democratic legislators have pushed for a temporary extension that would provide these individuals with relief at the beginning of the year while allowing additional time for them to debate broader reforms. Republicans have pushed back on an extension, instead arguing that they should be reformed or that policymakers should lean on health savings accounts or direct stipends.
The GAO's results could catalyze the GOP pushback, per Politico. Jason Smith, R-Mo., who chairs the House Ways and Means Committee, told the outlet that the analysis is a "smoking gun that shows how this broken system, shielded by Democrat policies, has led to the federal government shoveling tens of billions of tax dollars to insurance companies through identity fraud."