ACA Open Enrollment Begins for Most States as Premiums Rise and New Enrollment Barriers Loom

People shopping for Affordable Care Act coverage for the next plan year will encounter a number of changes, from higher premiums to tougher enrollment procedures and tighter limits on which immigrants qualify for subsidies.

Consumers should be ready to navigate those shifts as open enrollment begins in most states. Idaho, Connecticut and Massachusetts start earlier, and some states are already offering “window shopping” so people can preview rates.

Enrollment is expected to keep slipping overall, largely because the enhanced subsidies that had been in place expired at the end of 2025. Policy experts say that loss pushed millions to give up or lose coverage in the early months of the year.

The Trump administration, however, has pointed to the decline as evidence that its anti-fraud efforts are working, including an August move that canceled policies for 760,000 enrollees suspected of improper sign-up. A small number of those people have since regained coverage.

Bring Identification

One of the biggest changes is closer scrutiny of consumers and agents through new requirements aimed at preventing fraud and improper enrollments. For shoppers, that may mean a slower sign-up process.

According to a Centers for Medicare & Medicaid Services FAQ, the new rules apply only to people using agents or brokers to enroll through the federal marketplace, which operates in 29 states. They do not apply to state-based exchanges, which run under their own rules and have generally been more effective at stopping fraudulent enrollments.

Anyone using an agent in the federal marketplace will need a one-time confirmation code or link to approve that specific agent to enroll them or make changes on their behalf. The code or link will be sent by text, email or an automated phone call from one of the private enrollment platforms used by the agent. Returning consumers with outdated or incorrect contact information must first update it by calling the federal marketplace or submitting an application online.

In addition, consumers and policyholders considered “high-risk” must verify their own identity before authorizing an agent. CMS says this category includes first-time applicants, people with existing coverage who are changing states, consumers working with a new or different agent, and those whose monthly premium is $30 or less.

Joshua Brooker, who runs an insurance agency in Pennsylvania, said CMS appears to have targeted those groups because someone moving to a new state or switching brokers could be vulnerable to impersonation by a broker.

The $30 monthly threshold may reflect concerns that plans with very low or no premiums are easier for bad actors to enroll without permission, since the policyholder may never receive a bill. Brooker said some rogue agents even pay the low monthly amount themselves and still profit from commissions.

Still, he worries the rules are broad enough that “up to one in five consumers is going to have to do extra identity proofing” and may decide not to continue with coverage.

High-risk consumers must prove their identity through a CMS-approved third party such as Experian, which typically asks questions only the consumer should know. Those who fail may be told to contact Experian’s help desk or submit the application themselves by creating a healthcare.gov account, which requires uploading identification such as a driver’s license, passport, immigration papers or another form of ID.

“Some people may have trouble not because they’re not real, but because they don’t have a credit file, or have moved, or have changed names,” said Stacey Pogue, a senior research fellow at the Center on Health Insurance Reforms at Georgetown University.

She said the changes may be “an appropriate response by CMS that targets fraudulent enrollments but might also create extra hurdles.”

Fewer Brokers May Be Available

CMS also issued a rule in September that places a moratorium on brokers who are new to offering ACA coverage. Agents not registered with the federal marketplace in 2026 cannot help with 2027 enrollments until at least February, after open enrollment ends.

The agency said it acted because a disproportionate share of “significant compliance concerns” in 2026 came from newly registered agents or brokers. CMS also said it has removed “hundreds of non-compliant agents and brokers” this year.

Jason Fine, who operates a brokerage in Florida, said he understands the logic behind the changes and has repeatedly reported rogue agents to CMS after they switched his clients’ coverage without permission. But he said the updated rules also create concerns.

“Everything they are doing in the long term makes sense,” he said. “However, in the short term, I don’t know if they care about the chaos it will cause.”

He said the moratorium will make it much harder for small brokers to help clients this year. His agency and others often reduce staffing after open enrollment and then hire again later in the year. He had hoped to add as many as 10 agents to his core staff of about five, but recruiters have told him he is unlikely to find people who were registered for 2026 and are still available.

Fine said the rule may unintentionally help larger call centers, some of which did much of the marketing that regulators worried could lead to unauthorized switching. Those call centers often have larger year-round staffs.

“They can afford to keep a staff of 25 or 40 people all year long,” Fine said.

Agent groups have strongly criticized the directive. The National Association of Benefits and Insurance Professionals filed a lawsuit over the moratorium, arguing it unfairly affects 19,000 agents who may want to sell ACA plans for the next year.

“Just because you’re a new agent doesn’t mean you are fraudulent,” said Ronnell Nolan, president of Health Agents for America, another agent group that also sued seeking a temporary restraining order. “All these agencies who have trained new agents and paid thousands of dollars now have people who won’t be able to work.”

That leads to a key warning from Georgetown’s Pogue: consumers should not wait to make appointments. “If you rely on an agent or broker, and a lot of people do, their slots might fill up faster because there will be fewer of them to help with enrollment. I would reach out early.”

Costs Will Still Be a Major Concern

After Congress declined to renew the expiring enhanced subsidies, most people with ACA coverage saw their costs rise this year. Higher earners lost subsidies altogether, and double-digit premium increases left many paying substantially more.

Even so, most people buying ACA coverage for the next plan year will still get a subsidy. It will simply be less generous than before the extra assistance expired at the end of 2025.

Those subsidies are tied to the cost of benchmark plans, meaning the second-lowest-priced silver plan in a given area.

That structure helps offset premium increases.

“For most folks, overall affordability will stay about the same,” said Louise Norris, a health policy analyst for HealthInsurance.org. “That’s not to say it’s great, but if you were able to manage the premiums this year, it should be similar to that.”

But other pressures remain.

Last year’s average premium increase of 26 percent was the biggest in years. Insurers were partly reacting to fears that the loss of subsidies would cause healthier customers to leave the marketplace. Other commonly cited reasons for higher premiums include rising medical costs, inflation and labor shortages.

Premiums for the coming year are expected to rise by double digits again, though the increase, at 15 percent, is slightly smaller than last year’s.

Subsidies are based on income and phase out for households earning more than four times the federal poverty rate. In this enrollment period, that works out to $63,840 for a single person, $86,560 for a couple and $109,280 for a family of three, for example.

“The biggest issue we will face is affordability,” said Anne Petry, who co-owns Jaggi Petry Insurance & Investments in Forsyth, Ill., with her father and helps customers buy health insurance, including ACA plans. “There definitely will come a breaking point for people.”

Agents and other experts recommend not letting plans roll over automatically. Instead, consumers should go online and compare premiums and coverage, since both can change from year to year even for the same plan. New insurers may offer cheaper options, and shoppers should weigh deductibles and other out-of-pocket costs, not just monthly premiums. Several insurers, including Cigna, have also pulled back from part or all of their ACA service areas.

“If you just sit on the sidelines and let the policy auto-renew, you might miss out on what could be a better opportunity,” Norris said. She added that it is also important to review options because the out-of-pocket maximum for ACA plans is rising.

That maximum, which is the most a consumer must pay for deductibles, copayments and coinsurance before the plan is expected to cover remaining in-network care, was $10,600 for an individual and $21,200 for a family this year. It will increase by 13 percent to $12,000 for an individual and $24,000 for family coverage. Lower limits apply to households earning up to 2.5 times the federal poverty level.

The One Big Beautiful Bill Act also removes subsidy eligibility from many lawfully present immigrants, including people on temporary H-1B work visas, refugees, asylees, people with temporary protected status and those with pending green-card applications.

Three immigrant groups can still receive ACA subsidies: green-card holders with permanent legal status, certain Cuban and Haitian immigrants, and citizens of Micronesia, the Marshall Islands or Palau.

This article first appeared on KFF Health News and is republished here under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.