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Home Medicare

2026 ACA open enrollment period preview

by TheAdviserMagazine
10 months ago
in Medicare
Reading Time: 6 mins read
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2026 ACA open enrollment period preview
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As we approach the start of the annual open enrollment for 2026 individual and family health coverage, there are numerous changes consumers should know about. (See open enrollment dates for each state.) Some changes are nationwide, and others are state-specific.

Let’s dive in:

1. Higher premiums coupled with expiration of subsidy enhancements

One of the biggest changes for people who buy Marketplace health coverage is the net premium increases due to the impending expiration of the federal subsidy enhancements that have been in place since 2021. The question of extending these subsidy enhancements has been at the heart of the government shutdown stalemate. Without Congressional action, those subsidy enhancements will expire at the end of 2025, resulting in much higher net premiums in 2026.

Who’s affected: The 21.8 million Marketplace enrollees with subsidized coverage, who will experience sharply higher premium payments in 2026.
What you can do: Comparison shop during open enrollment to see if switching to a different Marketplace plan might be a cost-effective solution. Be wary, however, of scams and non-ACA-compliant options that might be marketed to you. There are significant drawbacks that come with non-ACA-compliant coverage.

In addition to the expiration of the subsidy enhancements, insurers are raising their pre-subsidy premiums by a weighted average of more than 23% nationwide. These premiums apply to people who aren’t eligible for premium subsidies, and they’re the largest overall premium increases the individual market has seen since 2018.

Who’s affected:

The 1.6 million Marketplace enrollees who already pay full-price for their coverage.
The 1.6 million Marketplace enrollees with income over 400% of the federal poverty level who will be subject to the “subsidy cliff” (and thus pay full price) in 2026 if the subsidy enhancements aren’t extended.
Anyone who buys ACA-compliant coverage outside the exchange.

What you can do: Comparison shop during open enrollment, and understand the rule changes (described below) about HSA-eligibility for Marketplace Bronze and Catastrophic plans, as well as increased access to lower-cost (but still ACA-compliant) Catastrophic plans.

2. Changes to state-funded subsidy programs in some states

Several states offer state-funded Marketplace subsidy programs, in addition to the ACA’s federally funded subsidies. These can be additional premium subsidies, additional cost-sharing subsidies, or both.

Some states are making changes to their state-funded subsidy programs for 2026. In several cases, the changes are designed to try to offset some of the reduction in federal premium subsidies that will happen if Congress doesn’t extend the federal subsidy enhancements.

For example, Colorado is switching its state-funded subsidy program from a cost-sharing reduction to additional premium subsidies. And New Mexico is designing its state-funded subsidy program to completely offset the reduction in federal subsidy funding.

A state-run reinsurance program isn’t the same as a subsidy program, but it does reduce premiums for people who aren’t eligible for Marketplace subsidies. Nevada is the latest state to debut a reinsurance program, which takes effect in 2026.

3. Higher limit for maximum out-of-pocket costs

The maximum allowable out-of-pocket limit for in-network care is increasing sharply for 2026, rising to $10,600 for a single individual and $21,200 for a family. These numbers are up from $9,200 and $18,400, respectively, in 2025.

Who’s affected: Potentially everyone enrolled in ACA-compliant coverage, including employer-sponsored plans and individual-market plans. But many plans have out-of-pocket limits well below the maximum allowable cap.
What you can do: Carefully review information you receive from your plan, noting whether there are any changes to your deductible and other out-of-pocket expenses. Consider other plans that are available in your area (or from your employer, if your employer offers multiple plans) to see if there are any that would better fit your needs and budget.

4. No cap on excess APTC (subsidy) repayment

Marketplace premium subsidies are a tax credit, but most people receive them in advance (APTC), with the money sent directly to their insurer each month. Each enrollee has to reconcile their APTC when they file their tax return. If their APTC was larger than it should have been, some or all of it has to be repaid to the IRS.

From 2014 through 2025, there has been a cap on how much excess APTC has to be repaid, depending on income. But that cap has been eliminated starting with the 2026 plan year. So if too much APTC is paid on your behalf in 2026, you’ll have to repay all of the excess to the IRS when you file your 2026 tax return.

Who’s affected: Potentially, anyone who receives APTC in 2026, depending on how closely their projected 2026 household income matches their actual 2026 household income.
What you can do: Be as precise as possible when providing the Marketplace with your income projection, and update your Marketplace account if you realize mid-year that your projection was off. And you can opt to take less APTC than the Marketplace calculates for you. If your APTC ends up being smaller than it’s supposed to be, you’ll be able to claim the additional amount when you file your tax return. (The premium tax credit is a refundable tax credit.)

5. No Marketplace subsidies for low-income recent immigrants

Starting January 1, 2026, recent immigrants whose household income is under the federal poverty level will no longer be eligible for Marketplace premium subsidies.

Who’s affected: Immigrants who have been in the U.S. less than five years (and thus aren’t eligible for Medicaid), with a household income below the federal poverty level.
What you can do: If you can increase your household income – perhaps by picking up an additional part-time job or gig work – to at least the federal poverty level ($15,650 for a single person, or $21,150 for a household of two), you may still be eligible for Marketplace subsidies in 2026.

6. Bronze and Catastrophic plans: HSA eligibility and increased access

Starting with the 2026 plan year, all Bronze and Catastrophic plans purchased in the Marketplace will be HSA-eligible. This will allow enrollees to contribute pre-tax funds to a health savings account, which will reduce their household income under the ACA-specific MAGI rules.

In addition, an ACA-compliant Catastrophic plan might be available to you in 2026 even if it wasn’t in the past. But Catastrophic plans cannot be used with Marketplace subsidies, so they’re generally only a good choice if there’s no possibility that your income will make you subsidy-eligible.

Who’s affected: Anyone who buys Marketplace coverage.
What you can do: Consider talking with a financial advisor to see if HSA contributions (or pre-tax retirement contributions) might get your income into the subsidy-eligible range, and whether this might fit with your overall financial goals.

7. Marketplace insurer entries and exits

As is always the case, the list of participating Marketplace insurers will change in some states in 2026. In some states, new insurers are joining the Marketplace, existing insurers are exiting the Marketplace, or both.

Who’s affected: Anyone whose Marketplace plan will no longer be available, or who lives in an area where a new carrier will offer plans.
What you can do: Pay close attention to notifications you receive from your insurer and the Marketplace. If your plan is ending, you’ll need to pick a new plan for 2026. If new plans are available in your area, comparison shop to determine whether they’d be a good fit for your household.

States where new insurers are entering the Marketplace for 2026 in at least some region of the state:

Alabama: Oscar
Florida: Community Care Network, and Cigna HMO
Minnesota: Health Partners
Mississippi: Oscar
Nevada: Caresource and Community Care Health Plan (a new Anthem affiliate, offering Battle Born State Plans)
Texas: Harbor Health
Washington: Wellpoint Washington

States where at least one current Marketplace insurer will no longer offer Marketplace plans in 2026. (Aetna’s exit accounts for the majority of these.):

Arizona: Aetna (and BCBSAZ is terminating PPO products, but will continue to offer HMOs.)
California: Aetna
Delaware: Aetna
Florida: Aetna
Georgia: Aetna
Illinois: Aetna, Health Alliance, and Quartz
Indiana: Aetna
Kansas: Aetna
Kentucky: CareSource
Maryland: Aetna
Michigan: Molina and UM Health Plan/Michigan Care
Mississippi: Primewell Health Services
Missouri: Aetna
Nevada: Aetna
New Jersey: Aetna
North Carolina: Aetna, and Celtic/WellCare
Ohio: Aetna, and AultCare
Texas: Aetna
Utah: Aetna
Virginia: Aetna (including Innovation Health)
Wisconsin: Molina and Chorus Community Health Plan
Wyoming: Mountain Health CO-OP

8. Illinois residents no longer using HealthCare.gov

For enrollment in 2026 coverage, Illinois residents will use Get Covered Illinois – which is run by the state – instead of HealthCare.gov. HealthCare.gov has transferred existing accounts for Illinois residents to Get Covered Illinois, which has sent access codes to enrollees. Enrollees can use the access code to  locate and update their accounts on the new platform.

Although the Marketplace platform is different in Illinois, this doesn’t affect the available coverage or the income-based subsidies that are available. However, as noted above, some insurers are exiting the Illinois Marketplace at the end of 2025.

9. District of Columbia working to establish a Basic Health Program

For 15 years, Washington, DC has provided Medicaid to adults with household income up to 215% of the federal poverty level (FPL). But starting in January 2026, this eligibility limit will drop to 138% of FPL.

However, DC has created a Basic Health Program (BHP), called Healthy DC Plan. It will be available to adults with household income above between 139% and 200% of FPL, and will have no premiums and no out-of-pocket costs for covered services. .

DC’s BHP committee clarified in October 2025 that the federal government had approved their BHP blueprint. Enrollment in the Healthy DC Plan will begin November 1, 2025, for coverage effective January 1, 2026.

Oregon and Minnesota already have BHPs, and New York has a similar program.

10. Additional benefits in Alaska, Washington, and the District of Columbia

Alaska, Washington, and the District of Columbia Marketplaces have revised their Essential Health Benefits (EHB) Benchmark plans for 2026 in, adding new coverage requirements.

The EHB Benchmark plan sets the minimum requirements for the coverage that must be offered by all individual and small-group health plans with effective dates of 2014 or later.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written hundreds of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.



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Tags: ACAEnrollmentOpenperiodPreview
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