Stay ahead of ACA changes

Major changes are coming to the Affordable Care Act that will significantly impact how your agency operates leading up to and during Open Enrollment 2026. Key changes include a new $5 rule for consumers on $0 plans, the end of the Special Enrollment Period (SEP) for consumers at ≤150% FPL, and the scheduled expiration of extended APTC (eAPTC) at the end of 2025. 

This page is your go-to resource for tracking the latest information and getting tools, training, and support from HealthSherpa to help you navigate these changes with confidence. 

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AGENT RESOURCES

ACA changes: Strategic insights for agencies

For agencies: Join the ACA changes: strategic insights for agencies webinar where we'll discuss, from an Agency perspective, the significant changes coming to the ACA and strategies to take to keep your agency prepared.

Start learning now

It will be important to prioritize active renewals for plan year 2026. Here's a quick refresher course on active and passive renewals.

Learn about the major ACA changes and what they mean for you and your consumers.

Preparing early will be key for OE 2026! Here are steps to start taking now so your OE is a success.

Watch the full ACA changes training webinar, available in English and Spanish:

POLICY UPDATES

What is changing

Special Enrollment Period ends for individuals at or below 150% FPL

The monthly Special Enrollment Period (SEP) for individuals at ≤ 150% FPL will be discontinued.

Effective: August 25, 2025

  • This change will restrict SEP eligibility for individuals unless they experience a Qualifying Life Event (QLE).
  • Many agents may decide to shift their work to a more seasonal operation vs a year-round operation.

$5 rule for auto-renewed $0 plans

Consumers eligible for $0 premium plans who don’t actively renew their subsidy eligibility will be required to pay $5 each month until they verify their eligibility information.

Effective: PY26 (November 1st, 2025)

  • You will need to actively enroll your clients with $0 premiums or they will have to pay $5/month for their auto-renewed plan.
  • Prioritize and collect documentation from these consumers pre-OE to make the enrollment process easier and more efficient.

Filing taxes and reconciling APTC required each year

Consumers will become ineligible for advance payments of the premium tax credit (APTC) if they didn't file their taxes and reconcile their APTC for one year (current regulations stipulate two years).

Effective: PY26 (November 1st, 2025)

  • Remind your clients to file taxes. Your current clients who are eligible for APTC may lose eligibility if they haven't filed taxes and reconciled APTC.
  • If APTC eligibility is lost, Cost Share Reduction (CSR) eligibility would also be lost.

Open Enrollment Period stays the same (Nov 1–Jan 15)

  • There will be no change to the annual Open Enrollment Period (OEP) for PY26.
  • OEP will shorten to Nov 1-Dec 15 with PY27.

 

Pre-enrollment verification required for Special Enrollment Period enrollments

Consumers are often asked to submit documentation proving they’ve experienced a qualifying life event (QLE) in order to verify their eligibility for a Special Enrollment Periods (SEPs).

Effective:

DMI for certain income variances

A Data Matching Issue (DMI) will be triggered when applicants attest to income above 100% FPL, but data sources show income below 100% FPL.

Effective: August 25, 2025 (remainder of PY25 and PY26)

  • The Marketplace checks a consumer's projected annual household income against data from tax returns and other federal data sources
  • Collect income documentation and remind clients to file taxes.

Expiration of enhanced subsidies (eAPTC)

Extended APTC (eAPTC) will expire at the end of 2025 without further legislative action. 

Effective: January 1, 2026

  • Premium payments for subsidized enrollees will increase nationwide when eAPTC subsidies expire. eAPTC expiration will affect all FPL tiers.

Other notable changes 

  • Carriers can require both the overdue amount and the initial premium for new coverage (unless prohibited by a state law). Effective: August 25, 2025
  • Deferred Action for Childhood Arrivals (DACA) recipients lose ACA eligibility. Effective: August 25, 2025
  • The automatic 60-day extension for applicants to provide documentation to verify household income inconsistencies is removed and income verification is required within 90 days. Effective: August 25, 2025
  • See the Marketplace Integrity and Affordability Final Rule.
     

Check back often for the latest information and resources from HealthSherpa. We're working hard to help you navigate these signficant changes.

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