https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-02-18 22:00:002025-02-19 14:27:29The Farmers Exchanges Announce Initial Estimate of Losses Attributed to the Southern California Wildfires
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-02-11 12:38:002025-02-11 14:06:56Farmers Insurance® Names Erik Toohey Head of Agency Owner Operations
When a new Commander in Chief takes office – and their party also controls both chambers of Congress – how quickly can they make changes to health policy? Is it realistic to think that policy changes can happen on “Day One” of a new administration?
The short answer is that administrations can set changes in motion starting on Day One. But government processes and regulations – including federal rulemaking protocols, court actions, and the legislative process – slow the process of implementing changes and may delay them for months or even years.
If you’re among the more than 24 million people who enrolled in 2025 Marketplace coverage during open enrollment,1 nothing will change about your coverage or premiums this year, since benefit and premium changes happen at the start of a plan year – January 1 for individual market coverage2 (barring unforeseen circumstances such as the mid-year carrier exit we saw in a few states in 2023).
How can a President start making changes on ‘Day One?’
An incoming President can sign executive orders, proclamations, and administrative orders starting on their first day in office.3 In January 2017, President Trump signed four executive orders during his first week in office,4 and in 2021, President Biden signed 24 executive orders during his first week in office.5
These documents do not require the support of Congress or federal agencies, but they can be blocked by the courts.6 Presidents often use these tools “to set a policy direction.”7 For example, President Trump issued an executive order in 2020 directing the Department of Health and Human Services (“HHS”) and Congress to reach a solution to protect consumers from surprise balance billing,8 and legislation addressing that matter was enacted later that year. But executive orders are also much easier to undo than legislation, since they can be reversed by an incoming president just as easily as they were implemented.7
An example of a health policy presidential proclamation is the immigrant health coverage proclamation that President Trump signed in 2019,9 although this was blocked by a court before it took effect10 and later revoked by President Biden.11
Executive orders can be used to guide federal agencies, and are often cited by those agencies when they issue proposed rulemaking.12
How quickly can a President make policy changes through federal rulemaking?
A president’s administration may also make policy changes through federal rulemaking, which plays an important role in setting health policy in the United States. For example, numerous sections of the Affordable Care Act (ACA) direct the Secretary of Health & Human Services to set rules and guidelines for the implementation of its provisions.13 These rules can evolve over time, as we’ve seen with ACA Section 1557 implementation.
But federal rulemaking is not an overnight process. Federal agencies must publish proposed rulemaking in the Federal Register and accept public comments for at least 30 days before considering those comments and then publishing a final rule.14
The Centers for Medicare & Medicaid Services (CMS), which oversees Medicare, Medicaid, and Marketplace health coverage, typically keeps the comment period open for at least 60 days. And the effective dates for final rules must be at least 30 days after they’re finalized (at least 60 days after finalization for “significant” and “major” rules).15
This is why it’s not a quick process for administrations to make regulatory changes. For example, consider the changes we’ve seen over the years regarding short-term health insurance:
The Obama administration proposed new short-term coverage rules in June 2016, finalized them in October 2016, and they took effect in January 2017, with enforcement delayed until April 2017 – more than 10 months after the proposal.16
The Trump administration proposed new short-term coverage rules in February 2018, finalized them in August 2018, and they took effect in October 201817 – more than seven months after they were proposed.
The Biden administration proposed new short-term coverage rules in July 2023, finalized them in March 2024, and they took effect in September 2024 – over a year after the proposal.
What types of health insurance policy changes are possible via rulemaking?
One important aspect of federal rulemaking related to the ACA happens each year, with the annual Notice of Benefit and Payment Parameters (NBPP).
The NBPP, which is hundreds of pages long, can be used for a wide range of changes that affect the health insurance Marketplaces. These include the length of open enrollment, access to special enrollment periods, user fees that insurers are charged to offer coverage via HealthCare.gov, rules for enhanced direct enrollment entities, setting guidelines for 1332 waiver proposals, rules and duties for Navigators, and many others.
The Biden administration published the proposed 2026 NBPP in October 2024,18 and finalized it in January 2025, in the waning days of the administration.19 But the incoming administration may make additional changes.
We saw this in 2021, with the 2022 NBPP: The outgoing Trump administration published the 2022 NBPP in January, finalizing some aspects of their proposed rule.20 Then the Biden administration issued a “Part Two” 2022 NBPP a few months later,21 and subsequently proposed additional rulemaking for 2022,22 which was finalized in September 2021.23
Separate invoices for coverage of abortion. The federal rulemaking process could be used to require Marketplace insurers to issue separate premium invoices for abortion coverage. A rule requiring this was finalized under the first Trump administration,24 but later overturned by a judge and repealed by the Biden administration.25
DACA eligibility for Marketplace enrollment. The federal rulemaking process could also be used to make changes to the Biden administration’s May 2024 rule that allowed DACA recipients to begin using the health insurance Marketplace in November 2024. This rule has already been challenged in court and DACA recipients are unable to use the Marketplace in the 19 states that challenged the rule.26
Additional legal challenges are possible, but a change to the federal rule itself is also possible under a new administration.
It’s also important to note that even after the federal rulemaking process is complete, the resulting rules can also be challenged in court. During the first Trump administration, there were 246 legal challenges to federal regulations, guidance documents, and agency memoranda. More than three-quarters of these cases resulted in either the court ruling against the federal agency, or the agency withdrawing the action due to the lawsuit.27
Funding for cost-sharing reductions (CSR). In October 2017, the Trump administration announced that they were cutting off funding for Marketplace cost-sharing reductions (CSR), effective immediately. The immediate effective date was unusual, but this stemmed from a lawsuit in which GOP lawmakers had argued that Congress had never allocated CSR funding.28
Federal funding for CSR did cease immediately, but eligible Marketplace enrollees continued to receive CSR benefits. Insurers in most states added the cost of CSR to the premiums for Silver plans (CSR benefits are only available on Silver plans). Premium subsidy amounts are based on the cost of the second-lowest-cost Silver plan, so the increased Silver plan premium resulted in larger premium subsidies for most enrollees, and this continues to be the case.29
Medicaid waivers. Medicaid waivers, including 1115 waivers,30 allow states to customize their Medicaid programs within various requirements and guardrails set by the federal government.
Medicaid waiver proposals are approved by CMS on a case-by-case basis, and the last two presidential administrations have taken very different approaches to this.31
Examples of Medicaid changes that could be made with a new administration’s approach to 1115 waivers include work requirements or premiums for some enrollees. But just like federal rule changes, the Medicaid waiver approval process includes a public comment period and a federal review period, so these are not changes that could be put into effect overnight.32
Is it possible for Congress and a President to overturn a predecessor’s rule quickly?
In most cases, a new administration has to go through the regular notice-and-comment rulemaking process to undo a regulation put in place by a previous administration. As described above, the evolving rules for short-term health insurance are an example of this.
But the Congressional Review Act (CRA) gives Congress and the President the ability to overturn a rule within 60 days of it being published in the Federal Register.33
So a CRA resolution passed by Congress and signed by the President could be used to overturn rules that were finalized in the last several weeks of the Biden administration. The CRA, enacted in 1996, has previously been used to overturn 20 rules.33
How can one-party control of the White House and Congress speed policy changes?
With one-party control of the White House and Congress, legislative action on health policy is certainly possible. In addition to the aforementioned CRA process for overturning federal agency rules, the regular legislative process could be used to make changes to existing laws or enact new laws.
Members of the newly sworn-in Congress have circulated a “menu of potential spending reductions for members to consider,” which includes Medicaid per-capita caps and work requirements, repealing the ACA’s Prevention and Public Health Fund, funding cost-sharing reductions (as noted above, de-funding CSR has resulted in higher government spending on premium subsidies), and repealing “major Biden health care rules.”35
But significant healthcare legislation would tend to have an effective date months or even years in the future, to give insurers, patients, and medical providers time to adapt. For example, consider the American Health Care Act (AHCA), a partial ACA repeal bill that passed the House in 2017 but failed in the Senate.36
The AHCA would have ended the enhanced federal funding that states get for Medicaid expansion under the ACA, but not until 2020.37 And it would also have replaced the ACA’s income-based Marketplace premium tax credits with age-based fixed dollar tax credits, but not until 2020.38
In summary, a new administration and Congress can make numerous changes to health policy. But while the process can begin immediately, the implementation of changes will generally be delayed by months or even years, depending on the policy.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
“Short-Term, Limited-Duration Insurance” Federal Register (Internal Revenue Service; Employee Benefits Security Administration; Health and Human Services Department). Aug. 3, 2018
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2025-01-17 16:21:372025-01-18 13:59:55Can a new President make health policy changes on ‘Day One?’
What will happen to Marketplace health insurance subsidy availability – and subsidy size – when the subsidy enhancements instituted under the American Rescue Plan (ARP) and extended by the Inflation Reduction Act (IRA) sunset after 2025? It’s a question that health reform experts and media who cover health reform have been asking as political control of the White House and Congress is about to shift in 2025.
To get an idea of how sunsetting the subsidy enhancements would impact subsidy eligibility and subsidy size, we looked at states with the highest average pre-subsidy Marketplace premiums, which in turn have among the largest subsidies. We found some examples of how premium subsidy amounts would decrease or be eliminated entirely when the ARP’s subsidy enhancements expire at the end of 2025 – unless Congress acts to further extend the enhancements.
How have ARP’s subsidy enhancements affected eligibility for Marketplace premiums?
Enrollment in the health insurance Marketplaces hit an all-time high for plan year 2024, with more than 21 million people signing up for private Marketplace plans during the open enrollment period for 2024 coverage.1 The record high enrollment, along with earlier record highs set in 2022 and 2023,2 was driven in part by the premium subsidy enhancements that were put in place by the American Rescue Plan and extended through 2025 by the Inflation Reduction Act (IRA).1
Of the nearly 21 million people who had effectuated Marketplace coverage as of early 2024, 93% were receiving advance premium tax credits (subsidies) that offset some or all of their monthly premiums.3 The federal government noted that as a result of the IRA’s extension of the ARP’s subsidy enhancements for an additional three years, four out of five people who enrolled through HealthCare.gov had access to plans with after-subsidy premiums of $10 or less per month in 2024.1
But the ARP subsidy enhancements are scheduled to sunset at the end of 2025 unless they’re extended again by Congress.4 When the subsidy enhancements end, Marketplace subsidy amounts will decrease for everyone who receives them – and will disappear altogether for some enrollees. Let’s take a look at why this would happen, and how enrollees in some states would be affected:
ACA subsidy rules prior to ARP
When the subsidy enhancements sunset at the end of 2025, the rules will revert – starting in 2026 – to the subsidy rules set by the ACA. Here’s how the ACA premium subsidy rules worked prior to the ARP: 5
Subsidies were not available if household income was more than 400% FPL, regardless of the percentage of income a household would have to spend to buy coverage. This resulted in a subsidy cliff at 400% FPL.
For subsidy-eligible enrollees, the subsidy amount was based on the enrollee having to pay a certain percentage of their household income for the benchmark plan (second-lowest-cost Silver plan). That percentage varied with household income, and ranged between roughly 2% and 9.5% of household income. (This is called the “applicable percentage” and the range was indexed each year by the IRS.)6
Temporary subsidy enhancements under the ARP and IRA
Now let’s take a look at how the ARP temporarily changed these rules, and how the IRA extended those changes through 2025:
The lower income threshold for premium subsidy eligibility did not change.
But the 400% FPL cap on subsidy eligibility was temporarily eliminated, so we haven’t had a subsidy cliff for the last few years. Instead, people with household income over 400% FPL are eligible for subsidies if the cost of the benchmark plan is more than 8.5% of their household income. (This assumes they meet other subsidy eligibility requirements, including not having access to Medicaid, premium-free Medicare Part A, or an employer’s plan that’s considered affordable and provides minimum value.)
For subsidy-eligible enrollees, the percentage of household income that the enrollee has to pay for the benchmark Silver plan has been reduced across the board. Instead of ranging from 2% to 9.5% of household income, it now ranges from 0% to 8.5% of household income.4 And again, that now applies to households with income above 400% FPL.
So the ARP subsidy enhancements, extended by the IRA, had two major effects:
They allow Marketplace enrollees with household income above 400% FPL to potentially qualify for premium subsidies.
They reduced the percentage of income that people pay for the benchmark plan at all income levels.
For example, under the original ACA rules, a person earning 150% FPL would pay 4% of their income for the benchmark plan,6 and their subsidy would cover the rest.
But under ARP rules, a person earning 150% FPL pays 0% of their income for the benchmark plan. Their subsidy covers the entire cost of the premium.7
We won’t know the 2025 FPL numbers (used to determine subsidy eligibility in 2026) until early 2025. And we also don’t yet know what the exact applicable percentage range would be for the 2026 plan year when the ARP subsidy enhancements sunset, as the IRS will have to calculate and publish those numbers. But it will be roughly in the range of 2% to 9.5%, with subsidies ending altogether at above 400% FPL. (To clarify: from 2015 through 2020, the range had increased four times and decreased twice. As of 2020, it stood at 2.06% to 9.78%.)8
Subsidies disappear for people with household incomes over 400% FPL
The return of the subsidy cliff would be particularly significant for older enrollees, since full-price premiums are based on age. (In almost all states, a 53-year-old will pay roughly twice as much as a 21-year-old, and a 64-year-old will pay three times as much as a 21-year-old.)9
It would also be particularly significant in areas where health insurance is more expensive than average. since the full premium would have to be paid by enrollees if their household income is over 400% FPL. (The national average pre-subsidy Marketplace premium in 2024 was about $603/month,10 but as we’ll discuss in a moment, some states have much higher averages.)
To illustrate this, let’s look at the ten states where average full-price Marketplace premiums were the highest for plan year 2024.3 We’ll consider a 55-year-old in each of those states, earning 405% of the 2024 FPL, which is used to determine subsidy eligibility for 2025. These enrollees are eligible for significant premium subsidies in 2025,11 as shown in the table below:
State
Avg. 2024 premium for people enrolled in Marketplace plans3
2025 subsidy for 55-year-old based on ZIP, earning 405% FPL
ZIP code for largest population in state
Avg. 2024 net premiums across all Marketplace enrollees in state14
Net 2025 premium for benchmark plan (age 55 earning 405% FPL)15,16,17,18,19
WV
$1,122
51,046
5,068
10%
$1,204/month
25301
$108
$432
AK
$972
27,464
5,192
19%
$1,229/month
99501
$222
$557
WY
$939
42,293
7,691
18%
$1,001/month
82001
$108
$431
CT
$896
129,000
26,500
21%
$863/month
06601 (Fairfield)
$230
$435
VT
$874
30,027
5,637
19%
$844/month
05401
$237
$431
DE
$725
44,842
6,901
15%
$500/month
19801
$188
$431
NY
$721
288,681
40,992
14%
$449/month
10001
$422
$432
ME
$714
62,586
9,811
16%
$477/month
04019
$223
$433
LA
$714
212,493
12,681
6%
$392/month
70032
$82
$432
AL
$706
386,195
13,787
4%
$600/month
35649
$64
$432
When the ARP subsidy enhancements sunset at the end of 2025, these individuals would not be eligible for any premium subsidies starting in 2026, assuming their 2026 household income is more than 400% of the 2025 FPL. So they could potentially go from receiving hundreds of dollars per month in subsidies in 2025 to receiving no subsidies at all in 2026. To continue to have coverage, they would have to pay the full premium amount.
These enrollees are not hypothetical. Across all Marketplace enrollees nationwide, the 55-64 age group has the highest total enrollment, with 5.1 million enrollees in 2024. And the next-closest age group is 45-54, with 4.1 million enrollees.20
And out of the 21.4 million people who selected Marketplace plans during the open enrollment period for 2024 coverage, 1.5 million reported incomes above 400% FPL.21 The chart above illustrates the percentage of enrollees in each state whose income is over 400% FPL. In eight of the ten states, this population accounts for at least 10% of Marketplace enrollment.
For everyone else, subsidies would get smaller
In addition to the return of the subsidy cliff for households earning more than 400% FPL, it’s important to understand that a return to the pre-ARP ACA subsidy rules would also result in smaller subsidies for everyone who continues to be subsidy-eligible. This is because at all income levels, people would have to pay a larger percentage of their income to purchase coverage.
Let’s consider a 45-year-old in Chicago who earns about $45,000 in 2025, or about 300% FPL. If this person enrolls in 2025 Marketplace coverage under the current enhanced subsidy rules, they will qualify for a subsidy of $227/month, and will have to pay $224/month in after-subsidy premiums to purchase the benchmark Silver plan.22 Their after-subsidy premiums amount to about 6% of their household income, as called for in the ARP applicable percentage table.23
But if the pre-ARP ACA subsidy rules were in place for 2025 instead, this person would have to pay roughly 9.5% of the household income for the benchmark plan. (Without the ARP subsidy enhancements extended by the IRA, the applicable percentage would have been indexed by the IRS, but it would have been close to 9.5%.)6 That would have amounted to about $356/month in after-subsidy premiums, instead of the $224/month that the aforementioned Chicagoan is paying under the ARP subsidy enhancements.
The Biden-Harris administration has noted that the ARP subsidy enhancements, and their extension by the IRA, resulted in not only record-high enrollment, but also an increase in the number of people who upgraded their Marketplace coverage from Bronze to a higher metal level.24 This makes sense, since the larger subsidies allowed people to buy more expensive coverage without increasing their net premiums.
Without the ARP subsidy enhancements, the Congressional Budget Office projects that Marketplace enrollment will drop from 22.8 million in 2025 to 18.9 million in 2026.25 And while millions of people will continue to have Marketplace coverage, it stands to reason the plan upgrades in response to the subsidy enhancements could reverse, with people opting to downgrade their coverage to keep the premiums affordable.26
Will the subsidy enhancements sunset?
Unless new legislation is enacted, the APR subsidy enhancements will sunset at the end of 2025. Insurers will submit their proposed 2026 rates and plans to state and federal regulators starting in the spring of 2025. So Congress would need to act before then – likely before March 31, 202527 – to avoid a scenario in which insurers are basing their rates on the lower enrollment28 and less-healthy risk pool29 that would be expected when the subsidy enhancements sunset.30
The Congressional Budget Office projects that without the ARP subsidy enhancements, gross premiums for the benchmark (second-lowest-cost Silver) plan would increase by an average of 4.3% in 2026.31
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-12-11 12:30:002024-12-11 14:34:34Recognizing an Improved Insurance Marketplace in California, Farmers Insurance® to Expand Its Coverage Options in the State
Already have an account?Log in to update your application, compare plans, and change or renew for 2025. Need help applying or have questions? Get help now.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-11-20 19:00:002024-11-21 15:40:39Act now for health coverage in 2025
Before you apply, check out 2025 coverage options in the Marketplace and get an idea if you qualify for savings. Answer a few quick questions to preview plans and prices before enrolling or renewing coverage for 2025 — you don’t even have to log in!
Enroll by December 15 for coverage that starts January 1.
Check to see if you’ll save on 2025 Marketplace coverage:
Find Marketplace premiums or check if you may qualify for Medicaid or Children’s Health Insurance Program (CHIP) coverage. Enter:
Your state
The number of people in your household (even if they don’t need health coverage)
Call the Marketplace Call Center.Call us to ask questions, start or finish your application, compare plans, or enroll. Get free, unbiased personal help.
Meet with an in-person assister. Search by your city, state, or ZIP code to find local people and organizations who can help you apply for coverage, choose a plan, and enroll. Some offer help in different languages.
Connect with an agent or broker.Agents and brokers can help you enroll in Marketplace coverage and can even take care of the whole process. (They might earn a commission from health insurance plans for enrolling you.)
Don’t wait to enroll for 2025 — most people qualify for savings, and plans cover preventive care, essential health benefits, and more!
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-10-31 20:00:002024-11-01 15:17:34Enroll in 2025 Marketplace health insurance: Apply today!
Open enrollment for 2025 ACA (Affordable Care Act)-compliant health insurance is just around the corner. Let’s take a look at the various changes that consumers should be aware of this fall.
DACA recipients may be eligible to use the Marketplace
DACA recipients are expected to be eligible to use the Marketplace for the first time, and able to qualify for income-based subsidies under the same eligibility rules that apply to any other applicant. As a result of this change, the government expects an additional 100,000 people to enroll in coverage for 2025.1
However, attorneys general in 19 states have filed a lawsuit in a federal district court, suing to have the DACA eligibility rule delayed and overturned. Oral arguments in that case were heard in mid-October, and it’s possible the court will issue a ruling shortly before the start of open enrollment.2 So there is still some uncertainty around the issue of DACA recipients’ ability to enroll in Marketplace coverage for 2025.
Georgia switches to state-run Marketplace platform
For 2025, there are some changes to these subsidies:
California: A state program that debuted in 2024 eliminated deductibles and other out-of-pocket costs for applicants with household incomes up to 250% of the federal poverty level (FPL).4 For 2025, the program is expanding. All Covered California applicants will be eligible for plans that have zero deductibles and reduced out-of-pocket costs.56
New Mexico: State out-of-pocket assistance (SOPA) benefits are being expanded so that plans with 90% actuarial value (equal to a Platinum plan) will be available to enrollees with household income up to 400% of FPL.7 In 2024, the income limit to qualify for these 90% actuarial value plans was 300% of the federal poverty level.8
Colorado: In 2024, Colorado’s state-funded cost-sharing reductions are available to enrollees with household income up to 250% of FPL. For 2025, the eligibility limit will be reduced to 200% of FPL, meaning fewer people will qualify. Applicants with household incomes up to 250% FPL will continue to be eligible for federal cost-sharing reductions, but applicants with income between 200% and 250% FPL will qualify for only the federal benefit, not the state-funded cost sharing reduction.9
New York: State-funded Marketplace subsidies are not currently available, but New York has received federal permission to offer state-funded subsidies starting in 2025.10 and 11 Under the terms of the state’s approved waiver amendment, applicants with income up to 400% of FPL will be eligible for new cost-sharing reductions, as well as additional cost-sharing assistance for diabetes care and pregnancy/postpartum care.12
Some Oregon enrollees may switch to Basic Health Program
Oregon debuted a Basic Health Program – Oregon Health Plan Bridge – in July 2024. Adults who earn more than 138% of FPL but not more than 200% of FPL are eligible to enroll.
Marketplace enrollees in that income range had the option of switching to Oregon Health Plan Bridge starting in July 2024, but were not required to do so.13
If these enrollees make any updates to their application (including changes to contact information, projected income, address, family size, a plan change made during open enrollment, etc.), their eligibility for Oregon Health Plan Bridge will be determined at that point. If they’re eligible for Oregon Health Plan Bridge, they will no longer be eligible for Marketplace subsidies.14
So a person who updates their Oregon Marketplace account during open enrollment with a projected income in the range that’s eligible for Oregon Health Plan Bridge will generally find that moving to that coverage is their best option for 2025, as they would otherwise have to pay full price to keep their private Marketplace plan.
A person who lets their plan auto-renew without making any changes to the application can potentially keep their Marketplace plan through 2026 (instead of switching to Oregon Health Plan Bridge) but the state notes that if an enrollee experiences any changes – such as a change in income – they are required to update their application.14
Individual and family premium increases average 6-7%
The insurers that offer individual/family health coverage have proposed overall average rate increases in the range of 6% to 7% for 2025. (The semi-weighted average is about 6.1%,15 and the median is about 7%.)16
Rates have been finalized already in some states, but are still under review in many states. You can see specific details for carriers in your state by selecting your state on this map.
But it’s important to understand that average rate changes are calculated based on full-price (unsubsidized) premiums, and most enrollees don’t pay full price. As of early 2024, 93% of Marketplace enrollees nationwide were receiving premium subsidies that offset some or all of the cost of their coverage.17
If you’re receiving a subsidy, the net (after-subsidy) premium you pay in 2025 will depend on how much your own plan’s premium changes, but also on how much the benchmark (second-lowest-cost Silver) plan premium changes because the cost of the benchmark plan is the basis for the amount of the premium subsidy. You’ll want to carefully review the notifications you receive from your insurer and the Marketplace to understand how your net premium will change if you renew your current coverage.
At least 18 states will see carrier entries or exits
As is the case every year, there will be some changes for 2025 in terms of which insurers offer Marketplace coverage in some states. In most states, the list of participating Marketplace insurers is the same for 2025 as it was for 2024. But in some states, new insurers are joining the Marketplace, while other states will see insurers exiting the Marketplace or leaving the individual market altogether.
We have details about 2025 insurer participation and premium changes on the pages we maintain for each state’s Marketplace, but here’s a summary of what we’re seeing in terms of carriers entering and exiting the Marketplaces for 2025:
Entries:
UnitedHealthcare – entering Indiana, Iowa, Nebraska, and Wyoming18
Aetna Life – exiting in Virginia (Aetna Health will continue to offer plans)3334
If your current insurer will be exiting your market at the end of 2024, you’ll need to select a new plan for 2025. You’ll have until Dec. 31 to pick a new plan with a Jan. 1 effective date.35 Depending on where you live, the Marketplace will likely automatically select a replacement plan for you if you don’t pick your own new plan. But it’s better to take an active role in picking your coverage.
Changes in insurer participation in the Marketplace obviously affect the plan options that are available to applicants, but they can also affect the benchmark plan premium – if the new or exiting insurer holds that position. Changes in the benchmark plan premium will affect premium subsidy amounts for everyone in that area who qualifies for subsidies, since subsidy amounts are calculated based on the cost of the benchmark plan.
New short-term health insurance rules affect access to coverage
From late 2018 through August 2024, federal rules permitted the sale of short-term health policies with total durations of up to three years. For people who have been relying on these longer-term short-term health plans, it’s important to understand what’s available during the open enrollment period for 2025 health coverage, and the potential consequences of letting open enrollment go by without selecting a new plan.
If your current short-term policy is scheduled to terminate at some point in 2025, you will not be able to purchase another longer duration short-term policy at that point. All available policies will be capped at no more than four months in total duration, which might mean that you’ll be uninsured at some point in 2025. And the termination of a short-term policy is not a qualifying life event that would trigger a special enrollment period and allow you to enroll in an individual/family health plan at that point.36
So if you’re currently enrolled in a short-term policy that will terminate in 2025, consider your Marketplace options during the upcoming open enrollment period. If you sign up for a Marketplace plan, it will provide coverage throughout 2025, and you may find that you’re eligible for federal or state financial assistance with the premiums.
Rules prevent unauthorized enrollments and plan changes
Over the last several months, CMS (the Centers for Medicare & Medicaid Services) has been taking steps to curb unauthorized enrollments and plan changes that were happening in states that use the federally run Marketplace (HealthCare.gov).
Starting in July, CMS implemented new rules that prevent brokers from adding themselves to a person’s HealthCare.gov account without the policyholder’s permission.37 (Unscrupulous brokers who did this in the past were able to get paid commissions for those accounts, and could make plan changes without the enrollee’s knowledge.)
If you want to assign a new broker to your account, you’ll either need to participate in a three-way call with the Marketplace call center and your new broker, or you’ll need to log into your HealthCare.gov account and add the new broker’s information.37 (Here’s how to do that.) This protocol is necessary if you want to switch from one broker to another, or if you were previously navigating the enrollment process on your own and you’ve decided you’d like a broker to help you.
Marketplace call center volume increases significantly once open enrollment is underway. So if you know that you’ll want to add a broker to your existing HealthCare.gov account or switch to a different broker – and you’re planning to utilize the three-way call to do so – you may want to address that issue before open enrollment begins.
If you’re in a state that runs its own Marketplace (meaning you don’t use HealthCare.gov), the Marketplace will have its own rules for adding a new broker to your account. The process varies from one state-run Marketplace to another, but your broker or the Marketplace will be able to explain what steps you’ll need to take if you want to add a new broker to your account.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-10-16 12:12:442024-10-16 15:16:39ACA open enrollment: what’s new for 2025
Open Enrollment for 2025 Marketplace coverage starts November 1.
Open Enrollment is right around the corner. Make sure you’re ready.
Image
Did you:
Gather basic information (PDF, 163 KB)? You can fill out your application faster if you’re ready with information like birthdates and Social Security Numbers (SSNs).
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-10-09 20:00:002024-10-10 16:19:31Are you ready for Open Enrollment?
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-10-02 18:05:002024-10-03 15:28:32Farmers Insurance Exchange Announces Pricing of its $300 million 7.000% Surplus Notes due 2064
Minneapolis, MN – Open enrollment for Affordable Care Act (ACA) health plans begins Nov. 1, and several changes could help bolster enrollment. Healthinsurance.org explains what’s changing, including new eligibility for DACA recipients, state-specific developments and new duration limits on short-term health insurance plans.
In most states, open enrollment for 2025 Marketplace coverage is Nov. 1, 2024, through Jan. 15, 2025.
“Open enrollment will be here soon, and several changes should be on people’s radar,” said Louise Norris, health policy analyst for healthinsurance.org.
DACA recipients now qualify for Marketplace coverage and subsidies
As a result of a Biden administration rule change, about 100,000 DACA recipients — people in the Deferred Action for Childhood Arrivals program — will be eligible for ACA Marketplace plans and federal premium subsidies, beginning Nov. 1. The new rule also makes DACA recipients eligible for Basic Health Program (BHP) coverage, although two of the three states that have BHPs already allow DACA recipients to enroll.
However, 19 attorneys general are seeking to have the DACA eligibility rule delayed and overturned. Oral arguments are scheduled for mid-October, and a ruling could come shortly before the start of open enrollment. So there is still some uncertainty around whether DACA recipients can enroll in Marketplace coverage for 2025.
Short-term health insurance plans include new duration limits
A new federal rule limits the duration of all short-term health insurance plans – effective Sept. 1, 2024, or later – to four months, including renewals. This is significantly less than the 36 months most states previously allowed.
This means that consumers would be able to buy a short-term plan on or after Sept. 1 and potentially keep it through the end of the year. But open enrollment is the first opportunity for many of these consumers to find replacement coverage through the Marketplace for 2025.
“The new federal rule prevents consumers from relying on short-term health insurance policies for longer periods of time,” Norris said. “Missing open enrollment this fall could leave these consumers with little to no full-year coverage options for 2025.”
Some states offer their own subsidies
Last year, 93 percent of Marketplace enrollees received federal premium tax credits, which lowers the cost of coverage. Enhanced federal premium subsidies under the American Rescue Plan (ARP) will still be available for 2025 thanks to the Inflation Reduction Act (IRA).
Nine states also offer state-funded subsidies, and for 2025 coverage, those subsidies will increase in California and New Mexico. New York will also add a new subsidy program for 2025 coverage.
Colorado, on the other hand, is reducing its subsidy program. Beginning in 2025, the eligibility threshold for Colorado state subsidies returns to 200% of the federal poverty level (FPL), down from 250% in 2024.
Insurers enter/exit markets for 2025
Numerous insurance carriers are entering state Marketplaces for 2025. Notably, WellPoint will now be available in Texas, Florida, and Maryland. Other insurers are also expanding into Florida (Simply Healthcare Plans); Indiana (UnitedHealthcare); Michigan (HAP CareSource); and New Hampshire (WellSense).
States that will see carriers exit Marketplaces include: Indiana, Kansas, New Mexico, Pennsylvania, South Carolina, Tennessee, Texas, Utah and Washington.
New consumer protections may impact enrollment process
In July, the federal government updated its protocols to protect consumers from unauthorized changes to their health coverage. The new policy requires that consumers verify brokers are authorized to assist with their enrollments on HealthCare.gov or on an approved enhanced direct enrollment platform. The steps consumers must take may vary, depending on the broker. States that run their own exchanges have their own protocols for ensuring that enrollments and plan changes are done with enrollees’ consent.
“This new requirement is intended to protect consumers so they aren’t fraudulently enrolled in a health plan or switched to a different plan without their knowledge,” explains Norris. “But it means consumers need to plan ahead, so they don’t run out of time to get enrollment help from a broker.”
Healthinsurance.org provides online resources for consumers about individual and family health insurance. Healthinsurance.org, owned by HealthInsurance.org, LLC, has been providing consumer information about health insurance and health reform for over 25 years.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-10-01 10:36:142024-10-01 15:35:40Changes to federal rules could draw newcomers to open enrollment, which starts Nov. 1
Open Enrollment for 2025 Marketplace health insurance starts on November 1! Take a few minutes today to get ready to streamline the enrollment process for a smoother experience.
Image
Prepare now to save time later
Use this checklist (PDF, 163 KB)to collect documents and information you may need before starting your application on November 1. Taking these steps now will save you time when you apply.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-09-25 20:00:002024-09-26 15:30:17Prepare now for 2025 Open Enrollment
Starting Nov. 1, 2024, Georgia residents will use a state-run health insurance enrollment platform, Georgia Access, to shop for and enroll in Marketplace health coverage for 2025.1 Here’s a look at the changes that consumers can expect:
How do Georgia residents currently enroll in Marketplace coverage?
From 2014 through 2023, Georgia relied fully on the federally run health insurance Marketplace, HealthCare.gov, for enrollment. For 2024, the state transitioned to a state-based Marketplace on the federal platform.2
This meant Georgia was responsible for some aspects of running the Marketplace, including operating and funding a Navigator program,3 and certifying the plans offered for sale via the Marketplace.2 But residents have continued to use HealthCare.gov to enroll in coverage with a 2024 effective date.
That changes for 2025 coverage, as Georgia will be running all aspects of their Marketplace, including the enrollment platform.
Can Georgia residents use Georgia Access to enroll in 2024 coverage?
No. Georgia residents who have a special enrollment period this fall and are using it to sign up for coverage that takes effect before the end of 2024 will still use HealthCare.gov to do that – even after Nov. 1. But then they will need to renew or change their coverage for 2025 using the Georgia Access platform.
To clarify, the Georgia Access platform cannot be used for enrollment with an effective date prior to Jan. 1, 2025, as it’s been approved by the federal government for enrollments starting with plan year 2025.1 The state-run enrollment platform will be operational as of Nov. 1, 2024, but only for coverage effective in 2025.
What’s changing for Georgia residents who need Marketplace health insurance?
If you’re enrolling in 2025 individual/family health coverage in Georgia, you’ll be using the Georgia Access enrollment platform instead of HealthCare.gov this fall. Existing HealthCare.gov accounts for Georgia residents will be transferred to Georgia Access. The Marketplace will send enrollees instructions for logging into the new Marketplace portal and accessing their accounts so that they can renew or change their coverage for 2025.
Georgia Access will also be operating the state’s Marketplace call center,4 as all state-run exchanges are required to do.5 So Georgia residents will no longer use HealthCare.gov’s call center if they need phone assistance with the enrollment process.
Those are the primary changes from a consumer perspective. But there will also be the same sort of changes that enrollees see every year, in terms of adjustments to plan designs, provider networks, and premiums – including changes to subsidy amounts that can affect net premiums.
What’s staying the same for Georgia Marketplace enrollees?
Although Georgia residents will no longer use HealthCare.gov to enroll in coverage for 2025, many aspects of the Marketplace will remain the same:
Open enrollment start date
Open enrollment in Georgia will begin Nov. 1, 2024, for coverage effective in 2025. This is the same schedule used by HealthCare.gov. Georgia residents will need to complete their enrollment by Dec. 16, 2024 to have coverage effective Jan. 1, 2025.6 (This is one day later than the Dec. 15, 2024 deadline for a Jan. 1 effective date on HealthCare.gov.7)
According to the Georgia Office of the Commissioner of Insurance, the end date for open enrollment had not yet been finalized as of late August 2024. In most states, including all of the states that use HealthCare.gov, it will end on Jan. 15, 2025. Georgia could opt to extend it beyond that, but cannot end it any earlier, under federal rules that were finalized in 2024.
Subsidy eligibility
After the transition to Georgia Access, enrollees will continue to have access to the same federal premium tax credits (premium subsidies) and cost-sharing reductions that are available via HealthCare.gov. Eligibility for these subsidies is the same regardless of whether a state runs its own exchange or uses the federal platform.
Premium tax credit eligibility is governed by IRS rules that are applicable nationwide.8 The amount of each enrollee’s tax credit depends on their household income and the cost of the second-lowest-cost Silver plan (benchmark plan) for that person. Since both of those can change from one year to the next, premium subsidy amounts also change from one year to the next. But the underlying structure of the subsidies is not changing with Georgia’s transition to a state-run Marketplace. In February 2024, 96% of Georgia’s Marketplace enrollees received advanced payments of premium tax credits.9
Cost-sharing reductions are available to enrollees with income between 100% and 250% of the federal poverty level as long as they select a Silver level plan.10 This will continue to be the case in Georgia’s state-run Marketplace.
Participating Marketplace carriers
Georgia’s health insurance Marketplace has nine participating carriers offering coverage in 2024, with varying coverage areas.11 All nine will continue to offer Marketplace coverage in 2025 (including one that will be offering plans under two separate entities).12
As is always the case – regardless of whether a state runs its own Marketplace – carriers can change their coverage areas from one year to the next. So although all of Georgia’s 2024 Marketplace insurers will continue to offer coverage in 2025, the specific plans and participating insurers in each area might change. Enrollees should carefully consider all of their available options before selecting a plan or renewing their coverage for 2025.
Georgia residents can continue to use an EDE
This is a significant difference between Georgia’s Marketplace and other state-run Marketplaces. Georgia is the first state-run Marketplace that will partner with enhanced direct enrollment (EDE) entities the way HealthCare.gov does.13
The enhanced direct enrollment process allows consumers in states that use HealthCare.gov to enroll in an on-exchange / Marketplace health plan through approved web brokers’ and insurers’ sites, without having to visit HealthCare.gov.14
Georgia Access is requiring its EDE partners to be certified as EDEs with HealthCare.gov.13 (An entity that doesn’t pass the federal Marketplace EDE certification requirements cannot serve as an EDE in Georgia.)4
So if you’re already accustomed to using an EDE to enroll in your Georgia Marketplace coverage – as opposed to going directly through HealthCare.gov – you’ll be able to continue to use that approach for 2025.
“The partnership between Georgia Access and private enrollment sites gives consumers the option of shopping and choosing Marketplace coverage through a third-party web site they may already be accustomed to using or with the assistance of a trusted insurance broker or agent,” says Dave Keller, president of INSXCloud, Inc., one of the participating enhanced direct enrollment platforms Georgia residents can use.* “We’re convinced the added enrollment flexibility will further increase enrollment in an already growing Georgia market.”
Georgia’s reinsurance program
The Georgia Access model is part of a 1332 waiver that was approved by CMS in 2020. Another part of that same 1332 waiver included a reinsurance program that took effect in Georgia in 2022.15
Georgia’s reinsurance program will continue to operate in 2025 the same way it does now. Reinsurance programs are in use in 17 states, including Georgia. Some of these states use HealthCare.gov while others run their own Marketplaces.
Reinsurance operates in the background, helping to keep premiums lower than they would otherwise be. Reinsurance primarily helps enrollees who don’t get premium subsidies (about 4% of Georgia Marketplace enrollees)16 and thus have to pay the full cost of their coverage.17 Georgia’s reinsurance program will continue to do this in 2025, as it is currently authorized through 2026, and can be extended after that.15
(The effects of reinsurance on subsidized enrollees are mixed; some pay higher net premiums as a result of the reinsurance program, since lower overall premiums result in smaller premium subsidies.17 But this is not affected by whether a state runs its own Marketplace or uses the federally run platform.)
If you already have coverage through the Georgia Marketplace in 2024, keep an eye out for any communications from HealthCare.gov, Georgia Access, and your health plan. You’ll receive instructions for claiming your account on Georgia Access, as well as information about how your current plan’s benefits and premium will change for 2025. And if you’re receiving a premium subsidy, you’ll also receive a notification of how much your subsidy will be in 2025.
As long as your current plan will still be available in 2025, it will auto-renew if you take no action during open enrollment. But it’s in your best interest to actively compare your plan options and decide whether you’d like to renew your existing plan or pick a different one.
If you worked with a broker or Navigator to enroll in your 2024 coverage, you can reach out to them to confirm that they’ll be certified with Georgia Access and will be able to help you with your 2025 coverage.
If you aren’t currently enrolled in a Georgia Marketplace plan, you’ll be able to use Georgia Access starting Nov. 1, 2024, to select a plan for 2025 – with income-based subsidies if you’re eligible.
* HealthInsurance.org, LLC and INSXCloud, Inc. indirectly share common corporate ownership.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-09-17 03:00:242024-09-17 15:19:56Georgia switches to state-run health insurance Marketplace for 2025 coverage
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-08-29 13:27:002024-08-29 15:05:32Outstanding US Law-Governed USD LIBOR Instruments Planned to Transition to Term SOFR
Under a Biden administration rule change, DACA (Deferred Action for Childhood Arrivals) recipients will be eligible to enroll through the health insurance Marketplace and apply for tax credits starting Nov. 1, 2024.1 The federal government estimates that 100,000 people will be newly eligible for Marketplace coverage under the rule.2
Ever since the ACA Marketplaces opened for business in the fall of 2013, they could be used by American citizens as well as lawfully present immigrants.3 But although DACA recipients are considered lawfully present for some purposes,4 they have never been allowed to enroll in coverage through the federally run HealthCare.gov Marketplace platform or most of the state-run health insurance Marketplaces.
The change in federal rules will allow DACA recipients in some states to shift from state-funded Medicaid or state-funded subsidy programs onto an ACA Marketplace plan with federal subsidies. For example, California,5 Colorado,6 and Washington7 already offer state-funded enrollment opportunities for DACA recipients. In most states, the new rules will make DACA recipients newly eligible for income-based financial assistance with their health coverage.2
Lawsuit challenges new rule regarding DACA health insurance eligibility
In August 2024, 15 states filed a lawsuit challenging the Biden administration’s decision to allow DACA recipients to enroll in Marketplace health coverage.8 Two of these states (Idaho and Virginia) run their own health insurance Marketplaces, while the other 13 use the federally run HealthCare.gov platform. The lawsuit – which cites the 2023 proposed rule’s estimate of 200,000 newly eligible individuals9 instead of the final rule’s 100,000 estimate – asks the federal court to postpone the effective date of the DACA health insurance Marketplace access rule.
The plaintiff states have also asked the court to vacate the rule on the grounds that the definition of “lawfully present” it proposes is “contrary to law and unreasonable, arbitrary, and capricious,”10 and enjoin the Centers for Medicare & Medicaid Services from enforcing the rule. So the implementation of the DACA health insurance Marketplace access rule could potentially change, pending the outcome of the litigation.
Who are DACA recipients?
The Deferred Action for Childhood Arrivals program was created in 2012 to protect young people who had arrived in the United States as children without proper immigration paperwork. The program temporarily protects them from deportation and allows them to work in the U.S. but does not grant them lawful status in the U.S.11 DACA recipients must renew their DACA status every two years.12
As a result of a 2023 court order, U.S. Citizenship and Immigration Services is no longer processing new DACA applications. But the agency is continuing to process renewal applications for people who received their DACA status before July 16, 2021.13
All DACA recipients – commonly referred to as “Dreamers” – are undocumented immigrants who came to the United States when they were children. But most Dreamers are not enrolled in DACA. Although an estimated 3.6 million Dreamers are living in the U.S., only about 530,000 of them are DACA recipients.14 Dreamers who are not enrolled in DACA will continue to be ineligible to enroll in Marketplace coverage in most of the country. (Washington does allow undocumented immigrants to use its Marketplace;15 Colorado has a separate platform, alongside the state-run Marketplace, that undocumented immigrants can use16).
The term Dreamers comes from the DREAM Act (Development, Relief and Education for Alien Minors Act), which would have given legal status to all eligible individuals who arrived in the U.S. as children without documentation. This legislation was first introduced in Congress in 2001 and has been reintroduced numerous times since then, but has never passed.17
Can DACA recipients enroll in Basic Health Program coverage?
Under the ACA, states have the option to create a Basic Health Program (BHP), although only three have done so (New York, Minnesota, and Oregon). A BHP provides coverage, with zero or low premiums, to people who don’t qualify for Medicaid and whose household income is up to 200% of the federal poverty level. (New York recently received federal permission to extend its BHP to 250% of the federal poverty level.)
The new federal rules allow DACA recipients to enroll in BHP coverage starting in November 2024,18 and the administration projects that roughly 1,000 DACA recipients will qualify for BHP coverage under the new rule.19
But from a consumer perspective, Oregon is the only state where DACA health insurance eligibility rules for BHP coverage will change in November 2024:
Minnesota has allowed DACA recipients to enroll in BHP coverage since 2017,20 using state funds to provide the coverage.21 The federal rule change means that the state will no longer need to fully fund BHP coverage for DACA recipients, but it won’t change anything about enrollees’ eligibility for coverage.
New York began allowing DACA recipients to enroll in BHP coverage in August 2024,22 under the terms of a 1332 waiver amendment.23
But Oregon’s BHP, which became operational in July 2024, does not currently allow DACA recipients to enroll.24 That will change in November 2024 due to the new federal rule, and DACA recipients will be eligible for 2025 coverage through Oregon’s BHP.18
If any other states choose to create a BHP in the future, coverage under those programs would be available to DACA recipients under the new federal rules.25
Can DACA recipients enroll in Medicaid?
DACA recipients can only enroll in Medicaid if a state opts to allow this and uses state funds to provide the coverage, which a few states do.26 State Medicaid programs are typically funded with a combination of state and federal funds, but federal funds cannot be used to provide Medicaid to DACA recipients.
The initially proposed federal rule change would have allowed DACA recipients to enroll in Medicaid and the Children’s Health Insurance Program (CHIP) but that change was not finalized. Instead, the Centers for Medicare & Medicaid Services (CMS) notes that “we are taking more time to evaluate and carefully consider the comments regarding our proposal with respect to Medicaid and CHIP.”27
However, DACA recipients will be able to qualify for income-based subsidies for Marketplace plan premiums even with income below the federal poverty level, as is the case for lawfully present immigrants who have been in the U.S. for under five years and are thus ineligible for Medicaid in most states.28
For U.S. citizens and immigrants who have been lawfully present in the U.S. for more than five years, premium subsidies are not available if their income is below the federal poverty level,29 as the ACA called for these applicants to be eligible for Medicaid instead.)
Can undocumented immigrants get health insurance?
The DACA health insurance rule change allows DACA recipients to enroll in Marketplace health coverage and qualify for federal premium subsidies. (As noted above, DACA recipients do not have lawful status in the U.S., but they are considered lawfully present for some purposes.)
But beyond that, federal funding cannot be used to provide health insurance for undocumented immigrants. And undocumented immigrants cannot enroll in coverage through the Marketplace unless a state has obtained federal permission to allow this. (Washington has done so,30 and Colorado established a separate enrollment platform that undocumented immigrants can use.31 Maryland intends to seek federal approval to allow undocumented immigrants to use its state-run Marketplace, albeit without any subsidies.32
Undocumented immigrants can obtain health coverage outside the Marketplace, either from an employer or directly purchased from an insurance company. And in some states, they can be eligible for state-funded Medicaid coverage. But about half of all undocumented immigrants in the U.S. are uninsured.33
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
https://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance.png512512wpmaddoxinshttps://www.maddoxinsurememphis.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2024-08-21 16:33:002024-08-21 23:14:32DACA news: 100,000 Dreamers become eligible for Marketplace health insurance
The Farmers Exchanges Announce Initial Estimate of Losses Attributed to the Southern California Wildfires
Farmers Insurance® Names Erik Toohey Head of Agency Owner Operations
Can a new President make health policy changes on ‘Day One?’
In this article
When a new Commander in Chief takes office – and their party also controls both chambers of Congress – how quickly can they make changes to health policy? Is it realistic to think that policy changes can happen on “Day One” of a new administration?
The short answer is that administrations can set changes in motion starting on Day One. But government processes and regulations – including federal rulemaking protocols, court actions, and the legislative process – slow the process of implementing changes and may delay them for months or even years.
If you’re among the more than 24 million people who enrolled in 2025 Marketplace coverage during open enrollment,1 nothing will change about your coverage or premiums this year, since benefit and premium changes happen at the start of a plan year – January 1 for individual market coverage2 (barring unforeseen circumstances such as the mid-year carrier exit we saw in a few states in 2023).
How can a President start making changes on ‘Day One?’
An incoming President can sign executive orders, proclamations, and administrative orders starting on their first day in office.3 In January 2017, President Trump signed four executive orders during his first week in office,4 and in 2021, President Biden signed 24 executive orders during his first week in office.5
These documents do not require the support of Congress or federal agencies, but they can be blocked by the courts.6 Presidents often use these tools “to set a policy direction.”7 For example, President Trump issued an executive order in 2020 directing the Department of Health and Human Services (“HHS”) and Congress to reach a solution to protect consumers from surprise balance billing,8 and legislation addressing that matter was enacted later that year. But executive orders are also much easier to undo than legislation, since they can be reversed by an incoming president just as easily as they were implemented.7
An example of a health policy presidential proclamation is the immigrant health coverage proclamation that President Trump signed in 2019,9 although this was blocked by a court before it took effect10 and later revoked by President Biden.11
Executive orders can be used to guide federal agencies, and are often cited by those agencies when they issue proposed rulemaking.12
How quickly can a President make policy changes through federal rulemaking?
A president’s administration may also make policy changes through federal rulemaking, which plays an important role in setting health policy in the United States. For example, numerous sections of the Affordable Care Act (ACA) direct the Secretary of Health & Human Services to set rules and guidelines for the implementation of its provisions.13 These rules can evolve over time, as we’ve seen with ACA Section 1557 implementation.
But federal rulemaking is not an overnight process. Federal agencies must publish proposed rulemaking in the Federal Register and accept public comments for at least 30 days before considering those comments and then publishing a final rule.14
The Centers for Medicare & Medicaid Services (CMS), which oversees Medicare, Medicaid, and Marketplace health coverage, typically keeps the comment period open for at least 60 days. And the effective dates for final rules must be at least 30 days after they’re finalized (at least 60 days after finalization for “significant” and “major” rules).15
This is why it’s not a quick process for administrations to make regulatory changes. For example, consider the changes we’ve seen over the years regarding short-term health insurance:
What types of health insurance policy changes are possible via rulemaking?
One important aspect of federal rulemaking related to the ACA happens each year, with the annual Notice of Benefit and Payment Parameters (NBPP).
The NBPP, which is hundreds of pages long, can be used for a wide range of changes that affect the health insurance Marketplaces. These include the length of open enrollment, access to special enrollment periods, user fees that insurers are charged to offer coverage via HealthCare.gov, rules for enhanced direct enrollment entities, setting guidelines for 1332 waiver proposals, rules and duties for Navigators, and many others.
Here’s a summary of some of the changes implemented by the 2025 NBPP.
The Biden administration published the proposed 2026 NBPP in October 2024,18 and finalized it in January 2025, in the waning days of the administration.19 But the incoming administration may make additional changes.
We saw this in 2021, with the 2022 NBPP: The outgoing Trump administration published the 2022 NBPP in January, finalizing some aspects of their proposed rule.20 Then the Biden administration issued a “Part Two” 2022 NBPP a few months later,21 and subsequently proposed additional rulemaking for 2022,22 which was finalized in September 2021.23
Separate invoices for coverage of abortion. The federal rulemaking process could be used to require Marketplace insurers to issue separate premium invoices for abortion coverage. A rule requiring this was finalized under the first Trump administration,24 but later overturned by a judge and repealed by the Biden administration.25
DACA eligibility for Marketplace enrollment. The federal rulemaking process could also be used to make changes to the Biden administration’s May 2024 rule that allowed DACA recipients to begin using the health insurance Marketplace in November 2024. This rule has already been challenged in court and DACA recipients are unable to use the Marketplace in the 19 states that challenged the rule.26
Additional legal challenges are possible, but a change to the federal rule itself is also possible under a new administration.
It’s also important to note that even after the federal rulemaking process is complete, the resulting rules can also be challenged in court. During the first Trump administration, there were 246 legal challenges to federal regulations, guidance documents, and agency memoranda. More than three-quarters of these cases resulted in either the court ruling against the federal agency, or the agency withdrawing the action due to the lawsuit.27
Funding for cost-sharing reductions (CSR). In October 2017, the Trump administration announced that they were cutting off funding for Marketplace cost-sharing reductions (CSR), effective immediately. The immediate effective date was unusual, but this stemmed from a lawsuit in which GOP lawmakers had argued that Congress had never allocated CSR funding.28
Federal funding for CSR did cease immediately, but eligible Marketplace enrollees continued to receive CSR benefits. Insurers in most states added the cost of CSR to the premiums for Silver plans (CSR benefits are only available on Silver plans). Premium subsidy amounts are based on the cost of the second-lowest-cost Silver plan, so the increased Silver plan premium resulted in larger premium subsidies for most enrollees, and this continues to be the case.29
Medicaid waivers. Medicaid waivers, including 1115 waivers,30 allow states to customize their Medicaid programs within various requirements and guardrails set by the federal government.
Medicaid waiver proposals are approved by CMS on a case-by-case basis, and the last two presidential administrations have taken very different approaches to this.31
Examples of Medicaid changes that could be made with a new administration’s approach to 1115 waivers include work requirements or premiums for some enrollees. But just like federal rule changes, the Medicaid waiver approval process includes a public comment period and a federal review period, so these are not changes that could be put into effect overnight.32
Is it possible for Congress and a President to overturn a predecessor’s rule quickly?
In most cases, a new administration has to go through the regular notice-and-comment rulemaking process to undo a regulation put in place by a previous administration. As described above, the evolving rules for short-term health insurance are an example of this.
But the Congressional Review Act (CRA) gives Congress and the President the ability to overturn a rule within 60 days of it being published in the Federal Register.33
So a CRA resolution passed by Congress and signed by the President could be used to overturn rules that were finalized in the last several weeks of the Biden administration. The CRA, enacted in 1996, has previously been used to overturn 20 rules.33
How can one-party control of the White House and Congress speed policy changes?
With one-party control of the White House and Congress, legislative action on health policy is certainly possible. In addition to the aforementioned CRA process for overturning federal agency rules, the regular legislative process could be used to make changes to existing laws or enact new laws.
This would be necessary, for example, to make sweeping changes to the ACA (legislation to repeal the ACA was introduced in Congress in January 202534), or to change the Inflation Reduction Act’s provisions regarding Medicare drug coverage.
Members of the newly sworn-in Congress have circulated a “menu of potential spending reductions for members to consider,” which includes Medicaid per-capita caps and work requirements, repealing the ACA’s Prevention and Public Health Fund, funding cost-sharing reductions (as noted above, de-funding CSR has resulted in higher government spending on premium subsidies), and repealing “major Biden health care rules.”35
But significant healthcare legislation would tend to have an effective date months or even years in the future, to give insurers, patients, and medical providers time to adapt. For example, consider the American Health Care Act (AHCA), a partial ACA repeal bill that passed the House in 2017 but failed in the Senate.36
The AHCA would have ended the enhanced federal funding that states get for Medicaid expansion under the ACA, but not until 2020.37 And it would also have replaced the ACA’s income-based Marketplace premium tax credits with age-based fixed dollar tax credits, but not until 2020.38
In summary, a new administration and Congress can make numerous changes to health policy. But while the process can begin immediately, the implementation of changes will generally be delayed by months or even years, depending on the policy.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
Farmers Insurance® Opens Additional Relief Sites to Assist Customers Impacted by Southern California Wildfires
Farmers Insurance® Assisting Customers Impacted by Southern California Wildfires
How sunsetting ARP’s subsidy enhancements would affect ACA subsidy amounts
In this article
What will happen to Marketplace health insurance subsidy availability – and subsidy size – when the subsidy enhancements instituted under the American Rescue Plan (ARP) and extended by the Inflation Reduction Act (IRA) sunset after 2025? It’s a question that health reform experts and media who cover health reform have been asking as political control of the White House and Congress is about to shift in 2025.
To get an idea of how sunsetting the subsidy enhancements would impact subsidy eligibility and subsidy size, we looked at states with the highest average pre-subsidy Marketplace premiums, which in turn have among the largest subsidies. We found some examples of how premium subsidy amounts would decrease or be eliminated entirely when the ARP’s subsidy enhancements expire at the end of 2025 – unless Congress acts to further extend the enhancements.
How have ARP’s subsidy enhancements affected eligibility for Marketplace premiums?
Enrollment in the health insurance Marketplaces hit an all-time high for plan year 2024, with more than 21 million people signing up for private Marketplace plans during the open enrollment period for 2024 coverage.1 The record high enrollment, along with earlier record highs set in 2022 and 2023,2 was driven in part by the premium subsidy enhancements that were put in place by the American Rescue Plan and extended through 2025 by the Inflation Reduction Act (IRA).1
Of the nearly 21 million people who had effectuated Marketplace coverage as of early 2024, 93% were receiving advance premium tax credits (subsidies) that offset some or all of their monthly premiums.3 The federal government noted that as a result of the IRA’s extension of the ARP’s subsidy enhancements for an additional three years, four out of five people who enrolled through HealthCare.gov had access to plans with after-subsidy premiums of $10 or less per month in 2024.1
But the ARP subsidy enhancements are scheduled to sunset at the end of 2025 unless they’re extended again by Congress.4 When the subsidy enhancements end, Marketplace subsidy amounts will decrease for everyone who receives them – and will disappear altogether for some enrollees. Let’s take a look at why this would happen, and how enrollees in some states would be affected:
ACA subsidy rules prior to ARP
When the subsidy enhancements sunset at the end of 2025, the rules will revert – starting in 2026 – to the subsidy rules set by the ACA. Here’s how the ACA premium subsidy rules worked prior to the ARP: 5
Temporary subsidy enhancements under the ARP and IRA
Now let’s take a look at how the ARP temporarily changed these rules, and how the IRA extended those changes through 2025:
So the ARP subsidy enhancements, extended by the IRA, had two major effects:
For example, under the original ACA rules, a person earning 150% FPL would pay 4% of their income for the benchmark plan,6 and their subsidy would cover the rest.
But under ARP rules, a person earning 150% FPL pays 0% of their income for the benchmark plan. Their subsidy covers the entire cost of the premium.7
We won’t know the 2025 FPL numbers (used to determine subsidy eligibility in 2026) until early 2025. And we also don’t yet know what the exact applicable percentage range would be for the 2026 plan year when the ARP subsidy enhancements sunset, as the IRS will have to calculate and publish those numbers. But it will be roughly in the range of 2% to 9.5%, with subsidies ending altogether at above 400% FPL. (To clarify: from 2015 through 2020, the range had increased four times and decreased twice. As of 2020, it stood at 2.06% to 9.78%.)8
Subsidies disappear for people with household incomes over 400% FPL
The return of the subsidy cliff would be particularly significant for older enrollees, since full-price premiums are based on age. (In almost all states, a 53-year-old will pay roughly twice as much as a 21-year-old, and a 64-year-old will pay three times as much as a 21-year-old.)9
It would also be particularly significant in areas where health insurance is more expensive than average. since the full premium would have to be paid by enrollees if their household income is over 400% FPL. (The national average pre-subsidy Marketplace premium in 2024 was about $603/month,10 but as we’ll discuss in a moment, some states have much higher averages.)
To illustrate this, let’s look at the ten states where average full-price Marketplace premiums were the highest for plan year 2024.3 We’ll consider a 55-year-old in each of those states, earning 405% of the 2024 FPL, which is used to determine subsidy eligibility for 2025. These enrollees are eligible for significant premium subsidies in 2025,11 as shown in the table below:
When the ARP subsidy enhancements sunset at the end of 2025, these individuals would not be eligible for any premium subsidies starting in 2026, assuming their 2026 household income is more than 400% of the 2025 FPL. So they could potentially go from receiving hundreds of dollars per month in subsidies in 2025 to receiving no subsidies at all in 2026. To continue to have coverage, they would have to pay the full premium amount.
These enrollees are not hypothetical. Across all Marketplace enrollees nationwide, the 55-64 age group has the highest total enrollment, with 5.1 million enrollees in 2024. And the next-closest age group is 45-54, with 4.1 million enrollees.20
And out of the 21.4 million people who selected Marketplace plans during the open enrollment period for 2024 coverage, 1.5 million reported incomes above 400% FPL.21 The chart above illustrates the percentage of enrollees in each state whose income is over 400% FPL. In eight of the ten states, this population accounts for at least 10% of Marketplace enrollment.
For everyone else, subsidies would get smaller
In addition to the return of the subsidy cliff for households earning more than 400% FPL, it’s important to understand that a return to the pre-ARP ACA subsidy rules would also result in smaller subsidies for everyone who continues to be subsidy-eligible. This is because at all income levels, people would have to pay a larger percentage of their income to purchase coverage.
Let’s consider a 45-year-old in Chicago who earns about $45,000 in 2025, or about 300% FPL. If this person enrolls in 2025 Marketplace coverage under the current enhanced subsidy rules, they will qualify for a subsidy of $227/month, and will have to pay $224/month in after-subsidy premiums to purchase the benchmark Silver plan.22 Their after-subsidy premiums amount to about 6% of their household income, as called for in the ARP applicable percentage table.23
But if the pre-ARP ACA subsidy rules were in place for 2025 instead, this person would have to pay roughly 9.5% of the household income for the benchmark plan. (Without the ARP subsidy enhancements extended by the IRA, the applicable percentage would have been indexed by the IRS, but it would have been close to 9.5%.)6 That would have amounted to about $356/month in after-subsidy premiums, instead of the $224/month that the aforementioned Chicagoan is paying under the ARP subsidy enhancements.
The Biden-Harris administration has noted that the ARP subsidy enhancements, and their extension by the IRA, resulted in not only record-high enrollment, but also an increase in the number of people who upgraded their Marketplace coverage from Bronze to a higher metal level.24 This makes sense, since the larger subsidies allowed people to buy more expensive coverage without increasing their net premiums.
Without the ARP subsidy enhancements, the Congressional Budget Office projects that Marketplace enrollment will drop from 22.8 million in 2025 to 18.9 million in 2026.25 And while millions of people will continue to have Marketplace coverage, it stands to reason the plan upgrades in response to the subsidy enhancements could reverse, with people opting to downgrade their coverage to keep the premiums affordable.26
Will the subsidy enhancements sunset?
Unless new legislation is enacted, the APR subsidy enhancements will sunset at the end of 2025. Insurers will submit their proposed 2026 rates and plans to state and federal regulators starting in the spring of 2025. So Congress would need to act before then – likely before March 31, 202527 – to avoid a scenario in which insurers are basing their rates on the lower enrollment28 and less-healthy risk pool29 that would be expected when the subsidy enhancements sunset.30
The Congressional Budget Office projects that without the ARP subsidy enhancements, gross premiums for the benchmark (second-lowest-cost Silver) plan would increase by an average of 4.3% in 2026.31
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
Recognizing an Improved Insurance Marketplace in California, Farmers Insurance® to Expand Its Coverage Options in the State
APGA Tour’s Willie Mack III receives sponsor exemption to the 2025 Farmers Insurance Open®
Act now for health coverage in 2025
Open Enrollment is now. Start 2025 off right by enrolling in coverage for the new year.
For coverage to start:
Make time today for a few easy steps. Coverage may be more affordable and easier than you think.
Apply & enroll today:
Check out 2025 Marketplace coverage options – find, compare, & save!
Before you apply, check out 2025 coverage options in the Marketplace and get an idea if you qualify for savings. Answer a few quick questions to preview plans and prices before enrolling or renewing coverage for 2025 — you don’t even have to log in!
Enroll by December 15 for coverage that starts January 1.
Check to see if you’ll save on 2025 Marketplace coverage:
Apply now
Need help applying or have questions? Get help now.
Enroll in 2025 Marketplace health insurance: Apply today!
Don’t delay — enroll today! Open Enrollment for 2025 health insurance is here. Enroll in a new plan or change your coverage for the year ahead.
Enroll by December 15, so your coverage can start January 1. Open Enrollment ends on January 15, 2025.
Apply and enroll at HealthCare.gov
There are several ways to sign up for health coverage, but the quickest and easiest is to apply online. Here’s how to get started:
Follow these 4 simple steps to complete your enrollment.
Got questions? Help is available
Don’t wait to enroll for 2025 — most people qualify for savings, and plans cover preventive care, essential health benefits, and more!
Learn more about Marketplace plans
Preview 2025 plans & prices now!
Jump start Open Enrollment for 2025 coverage by previewing plans with personalized price estimates based on your estimated income and household size.
Preview personalized 2025 plans & prices
Preview 2025 plans & prices
Come back during Open Enrollment from November 1 – January 15 to get exact prices, compare plans, and enroll!
Need help estimating your income?
ACA open enrollment: what’s new for 2025
In this article
Open enrollment for 2025 ACA (Affordable Care Act)-compliant health insurance is just around the corner. Let’s take a look at the various changes that consumers should be aware of this fall.
DACA recipients may be eligible to use the Marketplace
DACA recipients are expected to be eligible to use the Marketplace for the first time, and able to qualify for income-based subsidies under the same eligibility rules that apply to any other applicant. As a result of this change, the government expects an additional 100,000 people to enroll in coverage for 2025.1
However, attorneys general in 19 states have filed a lawsuit in a federal district court, suing to have the DACA eligibility rule delayed and overturned. Oral arguments in that case were heard in mid-October, and it’s possible the court will issue a ruling shortly before the start of open enrollment.2 So there is still some uncertainty around the issue of DACA recipients’ ability to enroll in Marketplace coverage for 2025.
Georgia switches to state-run Marketplace platform
Georgia will be operating its own Marketplace (exchange) platform this fall. Starting Nov. 1, residents will use Georgia Access – or an approved enhanced direct enrollment entity3 – to enroll in or renew coverage for 2025. Georgia residents have used HealthCare.gov for enrollment since 2014 but will no longer be able to use that platform to shop for 2025 coverage and subsequent years.
State-funded health insurance subsidies change in several states
In addition to the ACA’s federal premium subsidies and cost-sharing reductions, several states offer additional state-funded subsidies that further offset enrollees’ premiums, out-of-pocket costs, or both.
For 2025, there are some changes to these subsidies:
Some Oregon enrollees may switch to Basic Health Program
Oregon debuted a Basic Health Program – Oregon Health Plan Bridge – in July 2024. Adults who earn more than 138% of FPL but not more than 200% of FPL are eligible to enroll.
Read our overview of Basic Health Programs.
Marketplace enrollees in that income range had the option of switching to Oregon Health Plan Bridge starting in July 2024, but were not required to do so.13
If these enrollees make any updates to their application (including changes to contact information, projected income, address, family size, a plan change made during open enrollment, etc.), their eligibility for Oregon Health Plan Bridge will be determined at that point. If they’re eligible for Oregon Health Plan Bridge, they will no longer be eligible for Marketplace subsidies.14
So a person who updates their Oregon Marketplace account during open enrollment with a projected income in the range that’s eligible for Oregon Health Plan Bridge will generally find that moving to that coverage is their best option for 2025, as they would otherwise have to pay full price to keep their private Marketplace plan.
A person who lets their plan auto-renew without making any changes to the application can potentially keep their Marketplace plan through 2026 (instead of switching to Oregon Health Plan Bridge) but the state notes that if an enrollee experiences any changes – such as a change in income – they are required to update their application.14
Individual and family premium increases average 6-7%
The insurers that offer individual/family health coverage have proposed overall average rate increases in the range of 6% to 7% for 2025. (The semi-weighted average is about 6.1%,15 and the median is about 7%.)16
Rates have been finalized already in some states, but are still under review in many states. You can see specific details for carriers in your state by selecting your state on this map.
But it’s important to understand that average rate changes are calculated based on full-price (unsubsidized) premiums, and most enrollees don’t pay full price. As of early 2024, 93% of Marketplace enrollees nationwide were receiving premium subsidies that offset some or all of the cost of their coverage.17
If you’re receiving a subsidy, the net (after-subsidy) premium you pay in 2025 will depend on how much your own plan’s premium changes, but also on how much the benchmark (second-lowest-cost Silver) plan premium changes because the cost of the benchmark plan is the basis for the amount of the premium subsidy. You’ll want to carefully review the notifications you receive from your insurer and the Marketplace to understand how your net premium will change if you renew your current coverage.
At least 18 states will see carrier entries or exits
As is the case every year, there will be some changes for 2025 in terms of which insurers offer Marketplace coverage in some states. In most states, the list of participating Marketplace insurers is the same for 2025 as it was for 2024. But in some states, new insurers are joining the Marketplace, while other states will see insurers exiting the Marketplace or leaving the individual market altogether.
We have details about 2025 insurer participation and premium changes on the pages we maintain for each state’s Marketplace, but here’s a summary of what we’re seeing in terms of carriers entering and exiting the Marketplaces for 2025:
Entries:
Exits:
If your current insurer will be exiting your market at the end of 2024, you’ll need to select a new plan for 2025. You’ll have until Dec. 31 to pick a new plan with a Jan. 1 effective date.35 Depending on where you live, the Marketplace will likely automatically select a replacement plan for you if you don’t pick your own new plan. But it’s better to take an active role in picking your coverage.
Changes in insurer participation in the Marketplace obviously affect the plan options that are available to applicants, but they can also affect the benchmark plan premium – if the new or exiting insurer holds that position. Changes in the benchmark plan premium will affect premium subsidy amounts for everyone in that area who qualifies for subsidies, since subsidy amounts are calculated based on the cost of the benchmark plan.
New short-term health insurance rules affect access to coverage
As of Sept. 1, 2024, consumers can no longer buy short-term health insurance with total durations longer than four months, including renewals, and non-renewable plans are capped at total durations of three-months.
From late 2018 through August 2024, federal rules permitted the sale of short-term health policies with total durations of up to three years. For people who have been relying on these longer-term short-term health plans, it’s important to understand what’s available during the open enrollment period for 2025 health coverage, and the potential consequences of letting open enrollment go by without selecting a new plan.
If your current short-term policy is scheduled to terminate at some point in 2025, you will not be able to purchase another longer duration short-term policy at that point. All available policies will be capped at no more than four months in total duration, which might mean that you’ll be uninsured at some point in 2025. And the termination of a short-term policy is not a qualifying life event that would trigger a special enrollment period and allow you to enroll in an individual/family health plan at that point.36
So if you’re currently enrolled in a short-term policy that will terminate in 2025, consider your Marketplace options during the upcoming open enrollment period. If you sign up for a Marketplace plan, it will provide coverage throughout 2025, and you may find that you’re eligible for federal or state financial assistance with the premiums.
Rules prevent unauthorized enrollments and plan changes
Over the last several months, CMS (the Centers for Medicare & Medicaid Services) has been taking steps to curb unauthorized enrollments and plan changes that were happening in states that use the federally run Marketplace (HealthCare.gov).
Starting in July, CMS implemented new rules that prevent brokers from adding themselves to a person’s HealthCare.gov account without the policyholder’s permission.37 (Unscrupulous brokers who did this in the past were able to get paid commissions for those accounts, and could make plan changes without the enrollee’s knowledge.)
If you want to assign a new broker to your account, you’ll either need to participate in a three-way call with the Marketplace call center and your new broker, or you’ll need to log into your HealthCare.gov account and add the new broker’s information.37 (Here’s how to do that.) This protocol is necessary if you want to switch from one broker to another, or if you were previously navigating the enrollment process on your own and you’ve decided you’d like a broker to help you.
Marketplace call center volume increases significantly once open enrollment is underway. So if you know that you’ll want to add a broker to your existing HealthCare.gov account or switch to a different broker – and you’re planning to utilize the three-way call to do so – you may want to address that issue before open enrollment begins.
If you’re in a state that runs its own Marketplace (meaning you don’t use HealthCare.gov), the Marketplace will have its own rules for adding a new broker to your account. The process varies from one state-run Marketplace to another, but your broker or the Marketplace will be able to explain what steps you’ll need to take if you want to add a new broker to your account.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
Are you ready for Open Enrollment?
Open Enrollment for 2025 Marketplace coverage starts November 1.
Open Enrollment is right around the corner. Make sure you’re ready.
Did you:
Farmers Insurance Exchange Announces Pricing of its $300 million 7.000% Surplus Notes due 2064
Changes to federal rules could draw newcomers to open enrollment, which starts Nov. 1
Minneapolis, MN – Open enrollment for Affordable Care Act (ACA) health plans begins Nov. 1, and several changes could help bolster enrollment. Healthinsurance.org explains what’s changing, including new eligibility for DACA recipients, state-specific developments and new duration limits on short-term health insurance plans.
In most states, open enrollment for 2025 Marketplace coverage is Nov. 1, 2024, through Jan. 15, 2025.
“Open enrollment will be here soon, and several changes should be on people’s radar,” said Louise Norris, health policy analyst for healthinsurance.org.
DACA recipients now qualify for Marketplace coverage and subsidies
As a result of a Biden administration rule change, about 100,000 DACA recipients — people in the Deferred Action for Childhood Arrivals program — will be eligible for ACA Marketplace plans and federal premium subsidies, beginning Nov. 1. The new rule also makes DACA recipients eligible for Basic Health Program (BHP) coverage, although two of the three states that have BHPs already allow DACA recipients to enroll.
However, 19 attorneys general are seeking to have the DACA eligibility rule delayed and overturned. Oral arguments are scheduled for mid-October, and a ruling could come shortly before the start of open enrollment. So there is still some uncertainty around whether DACA recipients can enroll in Marketplace coverage for 2025.
Short-term health insurance plans include new duration limits
A new federal rule limits the duration of all short-term health insurance plans – effective Sept. 1, 2024, or later – to four months, including renewals. This is significantly less than the 36 months most states previously allowed.
This means that consumers would be able to buy a short-term plan on or after Sept. 1 and potentially keep it through the end of the year. But open enrollment is the first opportunity for many of these consumers to find replacement coverage through the Marketplace for 2025.
“The new federal rule prevents consumers from relying on short-term health insurance policies for longer periods of time,” Norris said. “Missing open enrollment this fall could leave these consumers with little to no full-year coverage options for 2025.”
Some states offer their own subsidies
Last year, 93 percent of Marketplace enrollees received federal premium tax credits, which lowers the cost of coverage. Enhanced federal premium subsidies under the American Rescue Plan (ARP) will still be available for 2025 thanks to the Inflation Reduction Act (IRA).
Nine states also offer state-funded subsidies, and for 2025 coverage, those subsidies will increase in California and New Mexico. New York will also add a new subsidy program for 2025 coverage.
Colorado, on the other hand, is reducing its subsidy program. Beginning in 2025, the eligibility threshold for Colorado state subsidies returns to 200% of the federal poverty level (FPL), down from 250% in 2024.
Insurers enter/exit markets for 2025
Numerous insurance carriers are entering state Marketplaces for 2025. Notably, WellPoint will now be available in Texas, Florida, and Maryland. Other insurers are also expanding into Florida (Simply Healthcare Plans); Indiana (UnitedHealthcare); Michigan (HAP CareSource); and New Hampshire (WellSense).
States that will see carriers exit Marketplaces include: Indiana, Kansas, New Mexico, Pennsylvania, South Carolina, Tennessee, Texas, Utah and Washington.
New consumer protections may impact enrollment process
In July, the federal government updated its protocols to protect consumers from unauthorized changes to their health coverage. The new policy requires that consumers verify brokers are authorized to assist with their enrollments on HealthCare.gov or on an approved enhanced direct enrollment platform. The steps consumers must take may vary, depending on the broker. States that run their own exchanges have their own protocols for ensuring that enrollments and plan changes are done with enrollees’ consent.
“This new requirement is intended to protect consumers so they aren’t fraudulently enrolled in a health plan or switched to a different plan without their knowledge,” explains Norris. “But it means consumers need to plan ahead, so they don’t run out of time to get enrollment help from a broker.”
Healthinsurance.org provides online resources for consumers about individual and family health insurance. Healthinsurance.org, owned by HealthInsurance.org, LLC, has been providing consumer information about health insurance and health reform for over 25 years.
Contact:
hiomedia@afmcommunications.com
Prepare now for 2025 Open Enrollment
Open Enrollment for 2025 Marketplace health insurance starts on November 1! Take a few minutes today to get ready to streamline the enrollment process for a smoother experience.
Prepare now to save time later
Don’t miss the opportunity for affordable coverage on November 1! Until then, get more tips to help you prepare to apply for 2025.
Georgia switches to state-run health insurance Marketplace for 2025 coverage
In this article
Starting Nov. 1, 2024, Georgia residents will use a state-run health insurance enrollment platform, Georgia Access, to shop for and enroll in Marketplace health coverage for 2025.1 Here’s a look at the changes that consumers can expect:
How do Georgia residents currently enroll in Marketplace coverage?
From 2014 through 2023, Georgia relied fully on the federally run health insurance Marketplace, HealthCare.gov, for enrollment. For 2024, the state transitioned to a state-based Marketplace on the federal platform.2
This meant Georgia was responsible for some aspects of running the Marketplace, including operating and funding a Navigator program,3 and certifying the plans offered for sale via the Marketplace.2 But residents have continued to use HealthCare.gov to enroll in coverage with a 2024 effective date.
That changes for 2025 coverage, as Georgia will be running all aspects of their Marketplace, including the enrollment platform.
Can Georgia residents use Georgia Access to enroll in 2024 coverage?
No. Georgia residents who have a special enrollment period this fall and are using it to sign up for coverage that takes effect before the end of 2024 will still use HealthCare.gov to do that – even after Nov. 1. But then they will need to renew or change their coverage for 2025 using the Georgia Access platform.
To clarify, the Georgia Access platform cannot be used for enrollment with an effective date prior to Jan. 1, 2025, as it’s been approved by the federal government for enrollments starting with plan year 2025.1 The state-run enrollment platform will be operational as of Nov. 1, 2024, but only for coverage effective in 2025.
What’s changing for Georgia residents who need Marketplace health insurance?
If you’re enrolling in 2025 individual/family health coverage in Georgia, you’ll be using the Georgia Access enrollment platform instead of HealthCare.gov this fall. Existing HealthCare.gov accounts for Georgia residents will be transferred to Georgia Access. The Marketplace will send enrollees instructions for logging into the new Marketplace portal and accessing their accounts so that they can renew or change their coverage for 2025.
Georgia Access will also be operating the state’s Marketplace call center,4 as all state-run exchanges are required to do.5 So Georgia residents will no longer use HealthCare.gov’s call center if they need phone assistance with the enrollment process.
Those are the primary changes from a consumer perspective. But there will also be the same sort of changes that enrollees see every year, in terms of adjustments to plan designs, provider networks, and premiums – including changes to subsidy amounts that can affect net premiums.
What’s staying the same for Georgia Marketplace enrollees?
Although Georgia residents will no longer use HealthCare.gov to enroll in coverage for 2025, many aspects of the Marketplace will remain the same:
Open enrollment start date
Open enrollment in Georgia will begin Nov. 1, 2024, for coverage effective in 2025. This is the same schedule used by HealthCare.gov. Georgia residents will need to complete their enrollment by Dec. 16, 2024 to have coverage effective Jan. 1, 2025.6 (This is one day later than the Dec. 15, 2024 deadline for a Jan. 1 effective date on HealthCare.gov.7)
According to the Georgia Office of the Commissioner of Insurance, the end date for open enrollment had not yet been finalized as of late August 2024. In most states, including all of the states that use HealthCare.gov, it will end on Jan. 15, 2025. Georgia could opt to extend it beyond that, but cannot end it any earlier, under federal rules that were finalized in 2024.
Subsidy eligibility
After the transition to Georgia Access, enrollees will continue to have access to the same federal premium tax credits (premium subsidies) and cost-sharing reductions that are available via HealthCare.gov. Eligibility for these subsidies is the same regardless of whether a state runs its own exchange or uses the federal platform.
Participating Marketplace carriers
Georgia’s health insurance Marketplace has nine participating carriers offering coverage in 2024, with varying coverage areas.11 All nine will continue to offer Marketplace coverage in 2025 (including one that will be offering plans under two separate entities).12
As is always the case – regardless of whether a state runs its own Marketplace – carriers can change their coverage areas from one year to the next. So although all of Georgia’s 2024 Marketplace insurers will continue to offer coverage in 2025, the specific plans and participating insurers in each area might change. Enrollees should carefully consider all of their available options before selecting a plan or renewing their coverage for 2025.
Georgia residents can continue to use an EDE
This is a significant difference between Georgia’s Marketplace and other state-run Marketplaces. Georgia is the first state-run Marketplace that will partner with enhanced direct enrollment (EDE) entities the way HealthCare.gov does.13
The enhanced direct enrollment process allows consumers in states that use HealthCare.gov to enroll in an on-exchange / Marketplace health plan through approved web brokers’ and insurers’ sites, without having to visit HealthCare.gov.14
Georgia Access is requiring its EDE partners to be certified as EDEs with HealthCare.gov.13 (An entity that doesn’t pass the federal Marketplace EDE certification requirements cannot serve as an EDE in Georgia.)4
So if you’re already accustomed to using an EDE to enroll in your Georgia Marketplace coverage – as opposed to going directly through HealthCare.gov – you’ll be able to continue to use that approach for 2025.
“The partnership between Georgia Access and private enrollment sites gives consumers the option of shopping and choosing Marketplace coverage through a third-party web site they may already be accustomed to using or with the assistance of a trusted insurance broker or agent,” says Dave Keller, president of INSXCloud, Inc., one of the participating enhanced direct enrollment platforms Georgia residents can use.* “We’re convinced the added enrollment flexibility will further increase enrollment in an already growing Georgia market.”
Georgia’s reinsurance program
The Georgia Access model is part of a 1332 waiver that was approved by CMS in 2020. Another part of that same 1332 waiver included a reinsurance program that took effect in Georgia in 2022.15
Georgia’s reinsurance program will continue to operate in 2025 the same way it does now. Reinsurance programs are in use in 17 states, including Georgia. Some of these states use HealthCare.gov while others run their own Marketplaces.
Reinsurance operates in the background, helping to keep premiums lower than they would otherwise be. Reinsurance primarily helps enrollees who don’t get premium subsidies (about 4% of Georgia Marketplace enrollees)16 and thus have to pay the full cost of their coverage.17 Georgia’s reinsurance program will continue to do this in 2025, as it is currently authorized through 2026, and can be extended after that.15
(The effects of reinsurance on subsidized enrollees are mixed; some pay higher net premiums as a result of the reinsurance program, since lower overall premiums result in smaller premium subsidies.17 But this is not affected by whether a state runs its own Marketplace or uses the federally run platform.)
What do Georgia enrollees need to do this fall?
If you need to obtain your own health coverage for 2025, you’ll be using the Georgia Access platform or an approved enhanced direct enrollment entity.
If you already have coverage through the Georgia Marketplace in 2024, keep an eye out for any communications from HealthCare.gov, Georgia Access, and your health plan. You’ll receive instructions for claiming your account on Georgia Access, as well as information about how your current plan’s benefits and premium will change for 2025. And if you’re receiving a premium subsidy, you’ll also receive a notification of how much your subsidy will be in 2025.
As long as your current plan will still be available in 2025, it will auto-renew if you take no action during open enrollment. But it’s in your best interest to actively compare your plan options and decide whether you’d like to renew your existing plan or pick a different one.
If you worked with a broker or Navigator to enroll in your 2024 coverage, you can reach out to them to confirm that they’ll be certified with Georgia Access and will be able to help you with your 2025 coverage.
If you aren’t currently enrolled in a Georgia Marketplace plan, you’ll be able to use Georgia Access starting Nov. 1, 2024, to select a plan for 2025 – with income-based subsidies if you’re eligible.
* HealthInsurance.org, LLC and INSXCloud, Inc. indirectly share common corporate ownership.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
Outstanding US Law-Governed USD LIBOR Instruments Planned to Transition to Term SOFR
DACA news: 100,000 Dreamers become eligible for Marketplace health insurance
Under a Biden administration rule change, DACA (Deferred Action for Childhood Arrivals) recipients will be eligible to enroll through the health insurance Marketplace and apply for tax credits starting Nov. 1, 2024.1 The federal government estimates that 100,000 people will be newly eligible for Marketplace coverage under the rule.2
Ever since the ACA Marketplaces opened for business in the fall of 2013, they could be used by American citizens as well as lawfully present immigrants.3 But although DACA recipients are considered lawfully present for some purposes,4 they have never been allowed to enroll in coverage through the federally run HealthCare.gov Marketplace platform or most of the state-run health insurance Marketplaces.
The change in federal rules will allow DACA recipients in some states to shift from state-funded Medicaid or state-funded subsidy programs onto an ACA Marketplace plan with federal subsidies. For example, California,5 Colorado,6 and Washington7 already offer state-funded enrollment opportunities for DACA recipients. In most states, the new rules will make DACA recipients newly eligible for income-based financial assistance with their health coverage.2
Lawsuit challenges new rule regarding DACA health insurance eligibility
In August 2024, 15 states filed a lawsuit challenging the Biden administration’s decision to allow DACA recipients to enroll in Marketplace health coverage.8 Two of these states (Idaho and Virginia) run their own health insurance Marketplaces, while the other 13 use the federally run HealthCare.gov platform. The lawsuit – which cites the 2023 proposed rule’s estimate of 200,000 newly eligible individuals9 instead of the final rule’s 100,000 estimate – asks the federal court to postpone the effective date of the DACA health insurance Marketplace access rule.
The plaintiff states have also asked the court to vacate the rule on the grounds that the definition of “lawfully present” it proposes is “contrary to law and unreasonable, arbitrary, and capricious,”10 and enjoin the Centers for Medicare & Medicaid Services from enforcing the rule. So the implementation of the DACA health insurance Marketplace access rule could potentially change, pending the outcome of the litigation.
Who are DACA recipients?
The Deferred Action for Childhood Arrivals program was created in 2012 to protect young people who had arrived in the United States as children without proper immigration paperwork. The program temporarily protects them from deportation and allows them to work in the U.S. but does not grant them lawful status in the U.S.11 DACA recipients must renew their DACA status every two years.12
As a result of a 2023 court order, U.S. Citizenship and Immigration Services is no longer processing new DACA applications. But the agency is continuing to process renewal applications for people who received their DACA status before July 16, 2021.13
All DACA recipients – commonly referred to as “Dreamers” – are undocumented immigrants who came to the United States when they were children. But most Dreamers are not enrolled in DACA. Although an estimated 3.6 million Dreamers are living in the U.S., only about 530,000 of them are DACA recipients.14 Dreamers who are not enrolled in DACA will continue to be ineligible to enroll in Marketplace coverage in most of the country. (Washington does allow undocumented immigrants to use its Marketplace;15 Colorado has a separate platform, alongside the state-run Marketplace, that undocumented immigrants can use16).
The term Dreamers comes from the DREAM Act (Development, Relief and Education for Alien Minors Act), which would have given legal status to all eligible individuals who arrived in the U.S. as children without documentation. This legislation was first introduced in Congress in 2001 and has been reintroduced numerous times since then, but has never passed.17
Can DACA recipients enroll in Basic Health Program coverage?
Under the ACA, states have the option to create a Basic Health Program (BHP), although only three have done so (New York, Minnesota, and Oregon). A BHP provides coverage, with zero or low premiums, to people who don’t qualify for Medicaid and whose household income is up to 200% of the federal poverty level. (New York recently received federal permission to extend its BHP to 250% of the federal poverty level.)
The new federal rules allow DACA recipients to enroll in BHP coverage starting in November 2024,18 and the administration projects that roughly 1,000 DACA recipients will qualify for BHP coverage under the new rule.19
But from a consumer perspective, Oregon is the only state where DACA health insurance eligibility rules for BHP coverage will change in November 2024:
Minnesota has allowed DACA recipients to enroll in BHP coverage since 2017,20 using state funds to provide the coverage.21 The federal rule change means that the state will no longer need to fully fund BHP coverage for DACA recipients, but it won’t change anything about enrollees’ eligibility for coverage.
New York began allowing DACA recipients to enroll in BHP coverage in August 2024,22 under the terms of a 1332 waiver amendment.23
But Oregon’s BHP, which became operational in July 2024, does not currently allow DACA recipients to enroll.24 That will change in November 2024 due to the new federal rule, and DACA recipients will be eligible for 2025 coverage through Oregon’s BHP.18
If any other states choose to create a BHP in the future, coverage under those programs would be available to DACA recipients under the new federal rules.25
Can DACA recipients enroll in Medicaid?
DACA recipients can only enroll in Medicaid if a state opts to allow this and uses state funds to provide the coverage, which a few states do.26 State Medicaid programs are typically funded with a combination of state and federal funds, but federal funds cannot be used to provide Medicaid to DACA recipients.
The initially proposed federal rule change would have allowed DACA recipients to enroll in Medicaid and the Children’s Health Insurance Program (CHIP) but that change was not finalized. Instead, the Centers for Medicare & Medicaid Services (CMS) notes that “we are taking more time to evaluate and carefully consider the comments regarding our proposal with respect to Medicaid and CHIP.”27
However, DACA recipients will be able to qualify for income-based subsidies for Marketplace plan premiums even with income below the federal poverty level, as is the case for lawfully present immigrants who have been in the U.S. for under five years and are thus ineligible for Medicaid in most states.28
For U.S. citizens and immigrants who have been lawfully present in the U.S. for more than five years, premium subsidies are not available if their income is below the federal poverty level,29 as the ACA called for these applicants to be eligible for Medicaid instead.)
Can undocumented immigrants get health insurance?
The DACA health insurance rule change allows DACA recipients to enroll in Marketplace health coverage and qualify for federal premium subsidies. (As noted above, DACA recipients do not have lawful status in the U.S., but they are considered lawfully present for some purposes.)
But beyond that, federal funding cannot be used to provide health insurance for undocumented immigrants. And undocumented immigrants cannot enroll in coverage through the Marketplace unless a state has obtained federal permission to allow this. (Washington has done so,30 and Colorado established a separate enrollment platform that undocumented immigrants can use.31 Maryland intends to seek federal approval to allow undocumented immigrants to use its state-run Marketplace, albeit without any subsidies.32
Undocumented immigrants can obtain health coverage outside the Marketplace, either from an employer or directly purchased from an insurance company. And in some states, they can be eligible for state-funded Medicaid coverage. But about half of all undocumented immigrants in the U.S. are uninsured.33
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
Health Insurance for Immigrants in Washington State” Washington Healthplanfinder. Accessed Aug. 19, 2024
Create a Basic Health Plan” United States of Care. June 23, 2023