People shopping for Affordable Care Act health insurance will encounter a mix of major and minor changes as open enrollment begins for 2027 coverage. Those changes include higher premiums, possible extra identity verification, delays when working with a broker, and new restrictions on which immigrants can receive subsidies.
Open enrollment has begun in most states.
Enrollment overall is expected to keep falling, largely because enhanced subsidies expired at the end of 2025. Policy experts say the end of those subsidies caused millions of people to drop coverage or lose it in the first months of this year.
The Trump administration, however, views the decline as a success, pointing to efforts to crack down on fraud. Those efforts included the August cancellation of policies covering 760,000 enrollees suspected of being improperly signed up. A small number of those people have since regained coverage.
Keep your ID handy
One of the biggest changes is stricter scrutiny of consumers and agents under new anti-fraud rules. For consumers, that could make enrollment slower.
The rules, described in a Centers for Medicare & Medicaid Services FAQ, apply only to people using agents or brokers to enroll through the federal marketplace, which serves 29 states. They do not apply to state-run exchanges, which operate under their own rules and have generally been more effective at stopping fraudulent sign-ups.
To begin with, anyone using an agent in the federal marketplace must receive a one-time confirmation code or link to authorize that specific agent to enroll them or make changes on their behalf. The code will be sent by text, email, or an automated phone call through one of the private enrollment platforms used by the agent. Returning consumers whose contact information is outdated will first have to call the federal marketplace themselves or submit an online application to update it.
Consumers and policyholders considered “high-risk” must also verify their own identity before authorizing an agent. CMS defines “high-risk” as first-time applicants, people with existing coverage whose application includes a change of state, consumers working with a new or different agent, and those with a monthly premium of $30 or less.
High-risk consumers must prove their identity through a CMS-approved third party such as Experian, the credit company, which typically asks questions only the consumer should be able to answer. People who do not pass may be asked to contact Experian’s help desk or file their own application by creating a healthcare.gov account, which requires uploading an ID such as a driver’s license, passport, immigration documents, or another form of identification.
There could be fewer brokers
In September, CMS issued a rule placing a moratorium on brokers new to selling ACA coverage. Agents who were not registered with the federal marketplace in 2026 will not be able to assist with 2027 enrollments until February at the earliest, which is after open enrollment ends.
CMS said the step was taken because a disproportionate share of “significant compliance concerns” in 2026 involved newly registered agents or brokers. The agency also said it has removed “hundreds of non-compliant agents and brokers” this year.
Jason Fine, who operates a brokerage in Florida, said he supports the idea behind the changes. He said he has repeatedly told CMS that rogue agents have switched his clients’ coverage without permission and that he wants the agency to act. Still, he said the revised rules also raise worries.
“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 firm and others often reduce staffing after open enrollment and then hire again near the end of the year. He had planned to add as many as 10 agents to his core team of about five, but recruiters have told him he is unlikely to find anyone who was registered for 2026 and is still available.
That has prompted an important warning from Georgetown’s Pogue: People 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 remain a major concern
After Congress did not extend the enhanced subsidies, most people buying ACA coverage saw their out-of-pocket costs rise. Higher earners lost subsidies entirely. Combined with double-digit premium increases, most people ended up paying substantially more for coverage.
Even so, most people who buy ACA coverage for next year will still qualify for a subsidy. It will simply be less generous than before the enhancements expired at the end of 2025.
The subsidies are tied to the premium cost of benchmark plans, meaning the second-lowest-priced silver-tier plan in a given area.
That helps cushion premium increases.
But other pressures are also affecting prices.
Last year’s average premium increase of 26% was the biggest in years. It was driven in part by insurers’ concern that the end of subsidies would push healthier people out of the marketplace. Other commonly cited reasons include higher medical costs overall, inflation, and labor shortages.
For the coming year, those pressures remain, with premiums expected to rise by double digits, though at 15% the increase is slightly smaller than last year’s.
Subsidies are based on income and are unavailable to households earning more than four times the federal poverty level. During this open enrollment period, that threshold is $63,840 for one person, $86,560 for a couple, and $109,280 for a family of three, for example.
Agents and other experts say consumers should not let their plans renew automatically. Instead, they should go online to compare premiums and coverage, since both can change from year to year even for the same plan. There may be cheaper options, including plans from new insurers, so they recommend comparing not only premiums but also deductibles and other costs. At the same time, several insurers, including Cigna, have dropped all or part of their ACA coverage areas.
The One Big Beautiful Bill Act, passed by Congress last year, 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.
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