It may come as no surprise that heat-related worker injury claims rise on hot days, but the magnitude of the increase is an eye-opener. As temperatures skyrocketed during early summer heat waves across the United States, the Workers Compensation Research …
Wireless carrier T-Mobile US said on Wednesday it is ending its diversity, equity and inclusion programs, under pressure from the Trump administration as it seeks regulatory approval for two major deals. T-Mobile said in a letter to Federal Communications Commission …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/T-Mobile-store-Las-Vegas-AdobeStock-580x387-1.jpeg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-11 10:26:062025-07-11 15:02:31T-Mobile Ending DEI Programs as it Seeks FCC Approval for 2 Deals
After Outlook users ran into issues accessing their email accounts late Wednesday and into Thursday, Microsoft says that affected systems are back online. Microsoft 365 first said that it was investigating an issue with Outlook Wednesday night, and later shared …
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By segmenting retail brokers into tiers using premium volume, profitability and strategic alignment as factors to define top tiers, carriers can start to win more business, according to a new consulting firm report. The report, How Insurers Can Win More …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/AdobeStock_169867404_Building-Business-Relationships-Partners-Agent-Meeting-In-Person-with-Carrier-Insurer-580x387-1.jpeg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-11 08:27:512025-07-11 15:02:33How Carriers Can Win More Retail Broker Biz: Report
After deadly flooding in central Texas in 1987, some thought they’d proven they could handle Mother Nature’s best punch. Then came this month’s horrific flash floods, when unfathomable amounts of rain fell in only hours and more than 100 people …
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The team of hurricane researchers at Colorado State University shaved off a storm from its original Atlantic hurricane season forecast, and now sees a “slightly” above normal season. High levels of observed Caribbean wind shear, which break up storms, is …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/hurricane-season-warning-1497715922-AdobeStock-580x387-1.jpeg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-11 01:19:102025-07-11 15:02:34CSU Hurricane Season Forecast Adjusted to ‘Slightly’ Above Normal
Arch Insurance North America said five of its executives were named to the newly-created roles of division presidents, effective Aug. 1. Linda Fallon has been named Division President, Consumer Business, which includes the Travel, Accident & Health unit and the …
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-11 01:09:172025-07-11 15:02:34People Moves: Arch Insurance NA Promotes 5 to Division Presidents
The Delaware Supreme Court rejected the legitimacy of expert testimony linking the heartburn drug Zantac to cancer, in a major win for makers of the product. In a unanimous ruling Thursday, the state’s highest court agreed with the argument of …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/Zantac-Bloomberg-580x387-1.jpg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-11 01:00:272025-07-11 15:02:35Delaware Top Court Sides With Zantac Makers in Cancer Claims
Though natural disasters cycle across seasons and regions in the U.S., it’s often a shocking discovery for property owners how expansive and expensive flood and water damage can be when a major storm devastates their homes, businesses and communities. That’s …
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The US slapped sanctions on individuals and companies linked to a scheme that involves recruiting North Koreans to pose as American tech workers and help fund Kim Jong Un’s regime. The Treasury Department’s Office of Foreign Assets Control imposed penalties …
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Copyright protections don’t just help individuals, they hold up a good part of the U.S. economy, according to a report from the U.S. Chamber of Commerce. The U.S. Chamber of Commerce’s 2023 report highlights industries like architecture, software, music, publishing, …
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-10 10:20:472025-07-10 15:08:45US Chamber Report Examines Copyright Value and Piracy Harms
A federal rule published in June 20251 will deliver significant changes to Affordable Care Act Marketplace enrollment, with some of the regulations becoming effective in August 2025. Here’s a look at the Marketplace Integrity and Affordability final rule’s changes and when they will take effect.
What is the federal rule and when does it take effect?
The Trump administration proposed the Marketplace Integrity and Affordability rule in early 2025, citing the need for new standards to ensure the integrity of the Marketplaces – including safeguards to protect consumers from improper enrollments.2 The proposed rule drew more than 26,000 public comments.3
The final rule’s effective date is August 25, 2025,4 with some of the rule’s provisions taking effect immediately on that date. Other provisions are applicable for the 2026 plan year or the 2027 plan year.
And, although the proposed rule called for the changes to be permanent, several are only applicable through the end of 2026.5
The first wave of changes – effective August 25, 2025
1. Pausing the special enrollment period for low-income individuals
Permanent? No. This is a pause rather than a termination. HHS has clarified that the low-income SEP will once again be available, at the option of each exchange, for plan year 2027.7
Rationale for rule: HHS stated that the low-income SEP played a significant role in allowing fraudulent enrollments that made headlines in 2024,8 and is potentially resulting in adverse selection, with people waiting until they’re sick to enroll in coverage.9
2. DACA recipients lose eligibility for coverage
Who’s affected: HHS estimates that 10,000 DACA recipients will lose Marketplace coverage as a result of this rule, and 1,000 people will lose Basic Health Program (BHP) coverage.10DACA recipients became eligible for Marketplace coverage in November 2024, but access to enroll in Marketplace plans was soon revoked in 19 states that sued to prevent DACA recipients from enrolling.11 DACA recipients in the rest of the country have continued to be eligible, but that will end in August 2025.
What changes: Deferred Action for Childhood Arrivals (DACA) individuals who are currently enrolled in the Marketplace will be disenrolled as of August 25, 2025.12 Under the same rule DACA recipients will also become ineligible for BHP coverage because they will no longer be considered “lawfully present” for the purpose of accessing Marketplace or BHP coverage, although only Minnesota and Oregon operate BHPs.
3. Stricter income verification for Marketplace applications
Who’s affected: Applicants with income mismatches or missing IRS data.
What changes: Marketplace applicants will need to provide proof of household income if the applicant attests to an income that doesn’t match the information the exchange gets from its trusted data sources (such as the Internal Revenue Service).13
This will include scenarios in which there are inconsistencies between what’s attested and what the Marketplace obtains from trusted data sources, such as the IRS, as well as scenarios in which the IRS doesn’t have tax return data on file for the applicant. It will also apply to situations in which the applicant attests to having a household income of at least 100% of the federal poverty level, but the exchange’s data sources indicate that’s not the case. In other words, the data sources show that the applicant is potentially in the coverage gap, but the applicant is attesting that they aren’t. The applicant will need to provide proof of their income to qualify for Marketplace financial assistance.
The final rule also permanently removes the current automatic 60-day extension to the regular 90-day window that applicants are given to provide requested income documentation.14
Permanent change? This rule change is temporary – through the end of 2026.13
4. Required payment of new coverage premiums if applicant has past-due premiums
Who’s affected: Enrollees who owe past-due premiums to an insurer and submit an application for a new policy with that insurer.
What changes: In this situation, the insurer will be allowed to add the past-due premium to the amount the applicant must pay to effectuate the new policy, as long as this is allowed under state law.15 If the applicant doesn’t pay the past-due premium, the insurer will be allowed to refuse to effectuate the new policy.
4 changes effective for enrollment in 2026 health plans
Open enrollment for 2026 coverage begins November 1, 2025. The following changes will apply to 2026 plans and/or the enrollment process that starts in November 2025:
1. Higher maximum out-of-pocket limits
Who’s affected: All Marketplace plan enrollees.
What changes: Starting in 2026, the new rule finalizes a methodology change for how maximum out-of-pocket limits are calculated. The result is that the highest allowable out-of-pocket limit for a single individual will be $10,600 in 2026.16
Under the previous methodology, the Biden administration had finalized a 2026 maximum out-of-pocket limit of $10,150, but that has been replaced by the new limit in this final rule.16
Impact: Higher out-of-pocket costs and less generous premium subsidies. Because the IRS uses the same premium indexing methodology to determine the percentage of income that Marketplace enrollees pay in after-subsidy premiums, the new methodology will also have the effect of reducing premium subsidies. This is because it will increase the percentage of income that people pay in after-subsidy premiums.17
2. $5 minimum premium for auto-renewed $0 premium plans
Who’s affected: Auto-renewed enrollees in $0 premium plans on HealthCare.gov. Although auto-renewal is not a consumer’s best option (it’s better to actively compare plan choices each year), it’s widely used. During the open enrollment period for 2025 coverage, nearly 20.2 million people renewed their Marketplace coverage, and 10.8 million of those people used auto-renewal.18
What changes: Under the new rules, if a person is enrolled in a $0 premium plan (meaning their premium subsidy covers the entire premium) and relies on auto-renewal for 2026, they will not have $0 premium coverage in 2026 until they reconfirm their eligibility information in their Marketplace account. Instead, they will have a minimum net premium of at least $5/month.19
Duration: This rule change is temporary, just for the 2026 plan year19 and does not apply to state-run exchanges.20
But H.R.1, the budget bill that was enacted on July 4, 2025 (known as the One Big Beautiful Bill Act), effectively calls for Marketplace auto-renewal to end altogether, starting with the 2028 plan year (the open enrollment period in the fall of 2027). From that point on, Marketplace enrollees will have to verify their ongoing eligibility for coverage and premium subsidies each year. Marketplaces will have the option to rely on automatic verification protocols for confirming enrollee information, in cases where it’s available via the Marketplace’s trusted data sources.212223
3. Bronze-to-Silver auto-renewal banned
Who’s affected: Marketplace enrollees with Bronze plans who are eligible for cost-sharing reductions (CSR) and let their coverage auto-renew.
Impact: Enrollees may miss out on CSR unless they take action.
Details: Under the existing guidance, if an applicant is eligible for CSR, enrolled in a Bronze plan, and a Silver plan is available in the same product (HMO, PPO, etc.), with the same provider network, and with equal or lesser after-subsidy premiums, the exchange can auto-renew the enrollee into the Silver plan. This allows the enrollee to take advantage of their CSR benefits, which are only available on Silver plans.
The final rule prohibits this protocol, starting with the 2026 plan year. Instead, the auto-renewal will keep the enrollee in their existing plan if it continues to be available.24
State-run exchanges “may retain their flexibility regarding their re-enrollment hierarchies at the discretion of the Secretary of Health and Human Services.” So a state-run exchange can seek HHS approval for a different approach to auto-renewal protocols.24
4. Pre-enrollment SEP eligibility verification
Who’s affected: Special enrollment period applicants in states with exchanges that use HealthCare.gov for enrollment.
What changes: In recent years, HealthCare.gov applicants using a SEP have only been required to provide proof of their SEP eligibility if the qualifying life event was the loss of other qualifying coverage.25 The final rule removes that limitation, allowing pre-enrollment eligibility verification for any qualifying life event.
The exchange will be required to conduct pre-enrollment SEP eligibility verification for at least 75% of new SEP enrollments.26
Permanent? No. This requirement will be in place only for the 2026 plan year.27
All states? The proposed rule called for this to apply nationwide, but it was only finalized for states that use HealthCare.gov.28 State-run exchanges will continue to have the option to verify applicants’ SEP eligibility or not (some already do so, while others do not).29
Changes effective for enrollment in 2027 health plans
Shorter open enrollment period
Who’s affected: Almost all Marketplace enrollees.
What changes: HHS had initially proposed a shorter open enrollment period starting in the fall of 2025, but the final rule pushes this out until the fall of 2026.30
So, the open enrollment period for plan year 2026 begins on November 1, 2025 and will continue through January 15, 2026 in most states. State-run exchanges will have the option to extend it even later than that, which several have historically done.
But starting in the fall of 2026, and for future years, open enrollment will be shorter:
In states that use gov, it will run from November 1 to December 15.
States that run their own exchanges will have the option to extend open enrollment, but only within certain parameters:
It must begin no later than November 1
It can’t continue past December 31
It can’t last longer than nine weeks.
All policies selected during open enrollment will take effect January 1.31
As is already the case, the open enrollment period will continue to apply both on-exchange and off-exchange.32
Why are some of the rule’s changes temporary?
HHS notes that the decision to make some of the rules temporary is due largely to the fact that the current premium subsidy enhancements are scheduled to sunset at the end of 2025. This will result in smaller premium subsidies and fewer people eligible for $0 premium plans, which HHS believes will mitigate “improper and fraudulent enrollment concerns.”33
But it’s also noteworthy that most of the provisions in the final rule were also incorporated (permanently) in the budget reconciliation bill passed by the U.S. House in May 2025, and some of them were in the Senate’s version that was ultimately enacted in July 2025213422
If the final rule made all of its provisions permanent, Congressional Republicans would not have been able to claim any tax savings from incorporating those changes into their budget bill, as the changes would already have been made via regulations.21
But for rules that sunset at the end of 2026, lawmakers might be able to claim budgetary savings for 2027 and subsequent years, since the budget bill incorporated some of the same provisions but on a longer-term basis. The budget bill includes a combination of measures that would increase federal spending and others that will decrease federal spending; reductions in federal spending are counted as budgetary savings when determining the total economic impact of the bill.21
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.
Property/casualty insurers have started to broadcast the fact that they have earned spots on Ward’s list of 50 top-performing insurance companies for 2025, but only one was named for 35 straight years—RLI Corp. In addition, there were three newcomers to …
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The five U.S. cities with the riskiest drivers are all located in the Northeast, according to Allstate’s 2025 America’s Best Drivers Report. The insurer listed Boston as the city where drivers were most likely to experience a collision, followed by …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/car-accident-580x387-1.jpg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-10 03:00:012025-07-10 15:08:47Northeast Cities Ranked Riskiest in National Allstate Driving Report
President Donald Trump vowed to push forward with his aggressive tariff regime in the coming days, stressing he would not offer additional extensions on country-specific levies set to now hit in early August while indicating he could announce substantial new …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/Trump-Bloomberg-580x387-1.jpg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-09 11:17:552025-07-09 15:16:41Trump Vows No Tariff Extension, Hardens Threats on Copper, Drugs
Global growth is slowing as US tariff policy reduces trade and heightens geopolitical uncertainty, which ultimately will lead to decelerating growth in insurance premiums, according to Swiss Re. Global GDP growth (adjusted for inflation) is expected to slow to 2.3% …
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Direct premiums written by U.S. managing general agents jumped to over $114 billion in 2024, according to the latest installment of an annual research series on the MGA market. The report titled “Managing General Agents: Built for What’s Next” is …
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Inshur said it as received a $35 million capital raise from alternative asset manager Trinity Capital to invest in research and development of artificial intelligence technology to support its embedded auto insurance policies within the autonomous vehicle market. The company …
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-09 08:34:082025-07-09 15:16:43Insurtech Inshur Raises $35 Million From Trinity Capital for US Expansion, AI Tech
The steady rise in false advertising claims against consumer-facing companies has exposed a major insurance protection gap. The drivers of these legal actions are many and varied and include consumers’ growing – and regularly-shifting – health preoccupations; sustainability concerns; patriotic …
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The State Department is warning U.S. diplomats of attempts to impersonate Secretary of State Marco Rubio and possibly other officials using technology driven by artificial intelligence, according to two senior officials and a cable sent last week to all embassies …
https://www.maddoxinsurememphis.com/wp-content/uploads/2025/07/Marco-Rubio-AP-580x387-1.jpg387580wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-07-08 15:14:092025-07-09 15:16:51Impostor Uses AI to Impersonate Rubio, Contact Foreign and US Officials
Report Shows Excessive Heat Pushes Worker Injury Risk Sky High
It may come as no surprise that heat-related worker injury claims rise on hot days, but the magnitude of the increase is an eye-opener. As temperatures skyrocketed during early summer heat waves across the United States, the Workers Compensation Research …
T-Mobile Ending DEI Programs as it Seeks FCC Approval for 2 Deals
Wireless carrier T-Mobile US said on Wednesday it is ending its diversity, equity and inclusion programs, under pressure from the Trump administration as it seeks regulatory approval for two major deals. T-Mobile said in a letter to Federal Communications Commission …
Microsoft Outlook Users Experience Hourslong Outage Impacting Email
After Outlook users ran into issues accessing their email accounts late Wednesday and into Thursday, Microsoft says that affected systems are back online. Microsoft 365 first said that it was investigating an issue with Outlook Wednesday night, and later shared …
How Carriers Can Win More Retail Broker Biz: Report
By segmenting retail brokers into tiers using premium volume, profitability and strategic alignment as factors to define top tiers, carriers can start to win more business, according to a new consulting firm report. The report, How Insurers Can Win More …
US Faces More Extreme Weather Events, but Is Society Doing Enough?
After deadly flooding in central Texas in 1987, some thought they’d proven they could handle Mother Nature’s best punch. Then came this month’s horrific flash floods, when unfathomable amounts of rain fell in only hours and more than 100 people …
CSU Hurricane Season Forecast Adjusted to ‘Slightly’ Above Normal
The team of hurricane researchers at Colorado State University shaved off a storm from its original Atlantic hurricane season forecast, and now sees a “slightly” above normal season. High levels of observed Caribbean wind shear, which break up storms, is …
People Moves: Arch Insurance NA Promotes 5 to Division Presidents
Arch Insurance North America said five of its executives were named to the newly-created roles of division presidents, effective Aug. 1. Linda Fallon has been named Division President, Consumer Business, which includes the Travel, Accident & Health unit and the …
Delaware Top Court Sides With Zantac Makers in Cancer Claims
The Delaware Supreme Court rejected the legitimacy of expert testimony linking the heartburn drug Zantac to cancer, in a major win for makers of the product. In a unanimous ruling Thursday, the state’s highest court agreed with the argument of …
What Flood Insurance Does and Does Not Cover
Though natural disasters cycle across seasons and regions in the U.S., it’s often a shocking discovery for property owners how expansive and expensive flood and water damage can be when a major storm devastates their homes, businesses and communities. That’s …
US Sanctions Target North Korean Fake-Tech-Worker Scheme
The US slapped sanctions on individuals and companies linked to a scheme that involves recruiting North Koreans to pose as American tech workers and help fund Kim Jong Un’s regime. The Treasury Department’s Office of Foreign Assets Control imposed penalties …
US Chamber Report Examines Copyright Value and Piracy Harms
Copyright protections don’t just help individuals, they hold up a good part of the U.S. economy, according to a report from the U.S. Chamber of Commerce. The U.S. Chamber of Commerce’s 2023 report highlights industries like architecture, software, music, publishing, …
New federal rule brings immediate changes to Marketplace enrollment
In this article
A federal rule published in June 20251 will deliver significant changes to Affordable Care Act Marketplace enrollment, with some of the regulations becoming effective in August 2025. Here’s a look at the Marketplace Integrity and Affordability final rule’s changes and when they will take effect.
What is the federal rule and when does it take effect?
The Trump administration proposed the Marketplace Integrity and Affordability rule in early 2025, citing the need for new standards to ensure the integrity of the Marketplaces – including safeguards to protect consumers from improper enrollments.2 The proposed rule drew more than 26,000 public comments.3
The final rule’s effective date is August 25, 2025,4 with some of the rule’s provisions taking effect immediately on that date. Other provisions are applicable for the 2026 plan year or the 2027 plan year.
And, although the proposed rule called for the changes to be permanent, several are only applicable through the end of 2026.5
The first wave of changes – effective August 25, 2025
1. Pausing the special enrollment period for low-income individuals
Who’s affected: This will apply nationwide, meaning low-income people will no longer have year-round access to enroll in Marketplace plans.6
Permanent? No. This is a pause rather than a termination. HHS has clarified that the low-income SEP will once again be available, at the option of each exchange, for plan year 2027.7
Rationale for rule: HHS stated that the low-income SEP played a significant role in allowing fraudulent enrollments that made headlines in 2024,8 and is potentially resulting in adverse selection, with people waiting until they’re sick to enroll in coverage.9
2. DACA recipients lose eligibility for coverage
Who’s affected: HHS estimates that 10,000 DACA recipients will lose Marketplace coverage as a result of this rule, and 1,000 people will lose Basic Health Program (BHP) coverage.10 DACA recipients became eligible for Marketplace coverage in November 2024, but access to enroll in Marketplace plans was soon revoked in 19 states that sued to prevent DACA recipients from enrolling.11 DACA recipients in the rest of the country have continued to be eligible, but that will end in August 2025.
What changes: Deferred Action for Childhood Arrivals (DACA) individuals who are currently enrolled in the Marketplace will be disenrolled as of August 25, 2025.12 Under the same rule DACA recipients will also become ineligible for BHP coverage because they will no longer be considered “lawfully present” for the purpose of accessing Marketplace or BHP coverage, although only Minnesota and Oregon operate BHPs.
3. Stricter income verification for Marketplace applications
Who’s affected: Applicants with income mismatches or missing IRS data.
What changes: Marketplace applicants will need to provide proof of household income if the applicant attests to an income that doesn’t match the information the exchange gets from its trusted data sources (such as the Internal Revenue Service).13
This will include scenarios in which there are inconsistencies between what’s attested and what the Marketplace obtains from trusted data sources, such as the IRS, as well as scenarios in which the IRS doesn’t have tax return data on file for the applicant. It will also apply to situations in which the applicant attests to having a household income of at least 100% of the federal poverty level, but the exchange’s data sources indicate that’s not the case. In other words, the data sources show that the applicant is potentially in the coverage gap, but the applicant is attesting that they aren’t. The applicant will need to provide proof of their income to qualify for Marketplace financial assistance.
The final rule also permanently removes the current automatic 60-day extension to the regular 90-day window that applicants are given to provide requested income documentation.14
Permanent change? This rule change is temporary – through the end of 2026.13
4. Required payment of new coverage premiums if applicant has past-due premiums
Who’s affected: Enrollees who owe past-due premiums to an insurer and submit an application for a new policy with that insurer.
What changes: In this situation, the insurer will be allowed to add the past-due premium to the amount the applicant must pay to effectuate the new policy, as long as this is allowed under state law.15 If the applicant doesn’t pay the past-due premium, the insurer will be allowed to refuse to effectuate the new policy.
4 changes effective for enrollment in 2026 health plans
Open enrollment for 2026 coverage begins November 1, 2025. The following changes will apply to 2026 plans and/or the enrollment process that starts in November 2025:
1. Higher maximum out-of-pocket limits
Who’s affected: All Marketplace plan enrollees.
What changes: Starting in 2026, the new rule finalizes a methodology change for how maximum out-of-pocket limits are calculated. The result is that the highest allowable out-of-pocket limit for a single individual will be $10,600 in 2026.16
Under the previous methodology, the Biden administration had finalized a 2026 maximum out-of-pocket limit of $10,150, but that has been replaced by the new limit in this final rule.16
Impact: Higher out-of-pocket costs and less generous premium subsidies. Because the IRS uses the same premium indexing methodology to determine the percentage of income that Marketplace enrollees pay in after-subsidy premiums, the new methodology will also have the effect of reducing premium subsidies. This is because it will increase the percentage of income that people pay in after-subsidy premiums.17
2. $5 minimum premium for auto-renewed $0 premium plans
Who’s affected: Auto-renewed enrollees in $0 premium plans on HealthCare.gov. Although auto-renewal is not a consumer’s best option (it’s better to actively compare plan choices each year), it’s widely used. During the open enrollment period for 2025 coverage, nearly 20.2 million people renewed their Marketplace coverage, and 10.8 million of those people used auto-renewal.18
What changes: Under the new rules, if a person is enrolled in a $0 premium plan (meaning their premium subsidy covers the entire premium) and relies on auto-renewal for 2026, they will not have $0 premium coverage in 2026 until they reconfirm their eligibility information in their Marketplace account. Instead, they will have a minimum net premium of at least $5/month.19
Duration: This rule change is temporary, just for the 2026 plan year19 and does not apply to state-run exchanges.20
But H.R.1, the budget bill that was enacted on July 4, 2025 (known as the One Big Beautiful Bill Act), effectively calls for Marketplace auto-renewal to end altogether, starting with the 2028 plan year (the open enrollment period in the fall of 2027). From that point on, Marketplace enrollees will have to verify their ongoing eligibility for coverage and premium subsidies each year. Marketplaces will have the option to rely on automatic verification protocols for confirming enrollee information, in cases where it’s available via the Marketplace’s trusted data sources.21 22 23
3. Bronze-to-Silver auto-renewal banned
Who’s affected: Marketplace enrollees with Bronze plans who are eligible for cost-sharing reductions (CSR) and let their coverage auto-renew.
What changes: The final rule permanently removes an auto-renewal protocol that HealthCare.gov adopted in 2024, allowing the Marketplace to switch a consumer from a Bronze plan to a Silver plan in some circumstances.
Impact: Enrollees may miss out on CSR unless they take action.
Details: Under the existing guidance, if an applicant is eligible for CSR, enrolled in a Bronze plan, and a Silver plan is available in the same product (HMO, PPO, etc.), with the same provider network, and with equal or lesser after-subsidy premiums, the exchange can auto-renew the enrollee into the Silver plan. This allows the enrollee to take advantage of their CSR benefits, which are only available on Silver plans.
The final rule prohibits this protocol, starting with the 2026 plan year. Instead, the auto-renewal will keep the enrollee in their existing plan if it continues to be available.24
State-run exchanges “may retain their flexibility regarding their re-enrollment hierarchies at the discretion of the Secretary of Health and Human Services.” So a state-run exchange can seek HHS approval for a different approach to auto-renewal protocols.24
4. Pre-enrollment SEP eligibility verification
Who’s affected: Special enrollment period applicants in states with exchanges that use HealthCare.gov for enrollment.
What changes: In recent years, HealthCare.gov applicants using a SEP have only been required to provide proof of their SEP eligibility if the qualifying life event was the loss of other qualifying coverage.25 The final rule removes that limitation, allowing pre-enrollment eligibility verification for any qualifying life event.
The exchange will be required to conduct pre-enrollment SEP eligibility verification for at least 75% of new SEP enrollments.26
Permanent? No. This requirement will be in place only for the 2026 plan year.27
All states? The proposed rule called for this to apply nationwide, but it was only finalized for states that use HealthCare.gov.28 State-run exchanges will continue to have the option to verify applicants’ SEP eligibility or not (some already do so, while others do not).29
Changes effective for enrollment in 2027 health plans
Shorter open enrollment period
Who’s affected: Almost all Marketplace enrollees.
What changes: HHS had initially proposed a shorter open enrollment period starting in the fall of 2025, but the final rule pushes this out until the fall of 2026.30
So, the open enrollment period for plan year 2026 begins on November 1, 2025 and will continue through January 15, 2026 in most states. State-run exchanges will have the option to extend it even later than that, which several have historically done.
But starting in the fall of 2026, and for future years, open enrollment will be shorter:
All policies selected during open enrollment will take effect January 1.31
As is already the case, the open enrollment period will continue to apply both on-exchange and off-exchange.32
Why are some of the rule’s changes temporary?
HHS notes that the decision to make some of the rules temporary is due largely to the fact that the current premium subsidy enhancements are scheduled to sunset at the end of 2025. This will result in smaller premium subsidies and fewer people eligible for $0 premium plans, which HHS believes will mitigate “improper and fraudulent enrollment concerns.”33
But it’s also noteworthy that most of the provisions in the final rule were also incorporated (permanently) in the budget reconciliation bill passed by the U.S. House in May 2025, and some of them were in the Senate’s version that was ultimately enacted in July 202521 34 22
If the final rule made all of its provisions permanent, Congressional Republicans would not have been able to claim any tax savings from incorporating those changes into their budget bill, as the changes would already have been made via regulations.21
But for rules that sunset at the end of 2026, lawmakers might be able to claim budgetary savings for 2027 and subsequent years, since the budget bill incorporated some of the same provisions but on a longer-term basis. The budget bill includes a combination of measures that would increase federal spending and others that will decrease federal spending; reductions in federal spending are counted as budgetary savings when determining the total economic impact of the bill.21
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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