2026 Agency Action Plan

Many changes are coming to the ACA including a $5 premium for $0 passive renewals, the expiration of enhanced subsidies, and the end of the Special Enrollment Period for ≤ 150% FPL. This year more than ever, early preparation is critical to your agency’s success.

This Agency Action Plan will help returning agents and agencies navigate these changes by focusing on client retention using HealthSherpa ’s tools that streamline prioritization and renewal. We're here to help you every step of the way!

OE 2026 will be different. Expect to:

Train and educate your agents on ACA changes, new workflows you will put in place, and new HealthSherpa features to help them navigate the ACA changes.
Actively renew your entire book of business, including those clients that would passively renew (auto-renew) in a typical year.
Spend more time on the enrollment process for most clients; longer enrollment times mean you might need more agent resources.
Collect documents prior to Open Enrollment to increase efficiency after November 1^st.
Engage early with clients and create a dialog before OE begins.

FFM Training for plan year 2026 will be available later this summer. To learn more about HealthSherpa's FFM Training program where agents can earn free CEUs, visit our FFM certification page.

Share the Agent Action Plan with your agents.

Share the Agent Video Library for courses on important ACA topics and how to make the most of the HealthSherpa platform.

Help your agents learn more about the ACA changes for plan year 2026 and how to use HealthSherpa to navigate them on our ACA Changes Resource Center.

This year, many consumers who would have passively renewed (auto-renewed) in previous years will need more support. Start your OE prep by reviewing your entire client list.

Educate your agents on how to identify their entire book, active and passive, and the importance of searching and claiming passive enrollments to encourage active renewals.

In HealthSherpa, you can view your client list along with DMIs, SVIs, payment status, and renewal factors to prioritize your outreach strategy for OE26:

Agency Insights: Get enhanced reporting for deeper visibility into your agency book of business.
Renewals section of Agency Tasks: Agents can see their full client list and filter by renewal factors to identify at-risk clients.
NEW! Client follow-ups tab: Agents can view their client list and all follow-ups in one place for easier prioritization. Policies with actions needed and with the soonest deadline will be at the top of the list.
NEW! Renewal factors have been added to help you identify clients affected by ACA changes, such as:
- Income near 150 FPL
- $5 monthly payment
- Tax return access denied
- Failure to reconcile APTC
- Carrier exit

It's important to start engaging with your clients early to increase the chances of educating and retaining your clients. Explain that to remain covered in 2026 they may need to provide additional information and/or review plans.

Resources to engage with your clients include consumer education materials, custom flyers, email templates, consumer readiness checklists and even social media templates.

Upload documents early and easily. Collect and store initial consent, required documentation, and client updates directly in HealthSherpa before Open Enrollment even begins, streamlining your workflow and avoiding delays once OE is underway.

The Special Enrollment Period is ending for clients with ≤150% FPL

New clients may no longer be SEP eligible beginning in May, and they will need a qualifying life event (QLE) to enroll outside of OEP.
Educate your team about all available QLEs so they are ready to explore alternative SEP opportunities with consumers.

Prepare to supply SEP pre-enrollment verification

For SEP enrollments, expect to submit documentation to verify your client’s QLE.
If the Marketplace can’t verify your client’s QLE, they may lose their SEP eligibility.