What We’re Watching: 2026 Open Enrollment Period
October 29, 2025 | By Miriam Lipschutz, MPP, and Heather Bates, MSW, ACC
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ACA’s 13th Open Enrollment looks different — here’s what we know
This year marks 15 years since the Affordable Care Act’s (ACA’s) passage, and November 1 will be the start of 13th Open Enrollment Period (OEP), when over 24 million people will look at their health coverage options for 2026.
However, this year’s OEP faces new uncertainty and challenges. Significant policy changes that impact Marketplace eligibility and enrollment, including the recently passed H. R. 1 (or One Big Beautiful Bill Act) and Marketplace Integrity and Affordability Final Rule have started to go into effect:
- End to the cap on repayment for any excess premium tax credit (PTC) for tax year 2026
- Elimination of the bronze-to-silver reenrollment crosswalk
- New methodology for the premium adjustment percentage
- Elimination of the low-income Special Enrollment Period (SEP)
Alongside these policy updates are changes to marketing and awareness through on-the-ground in-person help.
What these changes mean for consumers
Taken together, this year’s changes — with more to come in subsequent years — mean additional steps required in enrolling in coverage, convoluted decision making in enrolling in plans, less affordable plans, fewer Navigators to support enrollment, and fewer opportunities to enroll in coverage.
Most consequential is the expiration of the enhanced PTCs (ePTCs). These provisions that boosted coverage affordability since 2021 will end on December 31, 2025, unless Congress takes action to extend them. Even if the ePTCs ultimately get extended, consumers will already see premium costs more than double when the OEP begins on November 1.
Marketplace enrollment has increased significantly over the last few years for those earning less than 150% of the federal poverty level (FPL) because the ePTCs made plans much more affordable. In the 2025 OEP, almost half of all enrollees — about 11 million people — had income between 100-150% FPL. With the existing enhancements, those in this income bracket are eligible for $0 premium plans. Without the ePTCs, yearly premiums could jump from $0 to $1,600 for a family of four.
Over the next decade, the Congressional Budget Office estimates 2.4 million individuals will become uninsured due to H.R. 1, and an estimated 4.2 million will lose coverage from the expiration of the ePTCs alone. Texas and Florida are expected to see the largest coverage losses, with over a million people in each state expected to lose Marketplace coverage.
Consumers may be surprised by premium increases
Those receiving $0 premium plans due to the ePTCs, many of whom were new to Marketplace qualified health plan coverage over the last few years, may not be aware of or have received written notices of the premium increases until seeing their first bill in January.
In most states, consumers will only have until January 15 to change their plan selection unless eligible for a Special Enrollment Period; otherwise, they must maintain their higher cost plan or potentially forgo health insurance coverage all together. Additionally, they may encounter issues in accessing care or face unexpected costs if they choose to forgo coverage.
Example: A consumer may visit the doctor in January under their plan that they were automatically re-enrolled into in December. After the doctor’s visit, they receive a high monthly premium bill in the main that they cannot afford. They decide to drop their coverage, leaving the office visit and any other services received in 2026 uncovered and unpaid.
Consumers face the loss of affordability protection
H.R. 1 removed the cap for PTC repayments, meaning that individuals will be on the hook for repaying an excess PTC when they file their taxes in spring 2027 for the plan that they will choose this fall. This is especially worrisome for those with fluctuating incomes throughout the year due to gig economy or service industry work, or small business owners.
The Marketplace determines PTC eligibility and amount using the prior year’s IRS data unless the individual submits changes. If someone’s income has significantly changed, or is projected to change for the upcoming year, and they receive more PTCs than they are eligible for, the full excess amount will be owed at tax time.
Updating income at Open Enrollment and throughout the year with changes to income or household composition can help mitigate large, unexpected tax bills down the line.
How consumers can take action now
Consumers, their families, and assisters can focus on these key messages on taking action now to prepare for choosing coverage options for their household:
Mark important dates on your calendar.
- Open Enrollment starts November 1.
- Enroll in a plan by December 15 for coverage that starts January 1.
Review your current coverage.
- Log in to your state’s Marketplace website to review your current plan and costs.
- If your state uses HealthCare.gov: If you don’t know your login information, you can contact the Marketplace Call Center (1-800-318-2596) to get access to your account.
- If you live in a state with its own Marketplace: HealthCare.gov will guide you to your state’s website to log in.
Get your documents ready.
- Gather social security numbers and immigration documents.
- Get your income information.
- Pay stubs, W-2s
- Tax returns
- Make sure you have employer coverage information.
Update your Marketplace account.
- Ensure you can access your account
- Report any changes in your household, income, or address to see accurate plan options
- Update your preferred providers and prescriptions to make sure they are covered when you review available plans
Coverage options may be different for different members of a household, where children may be eligible for Medicaid or CHIP coverage. A certified Navigator or assister can provide guidance through these significant changes this OEP.
Transform Health can help navigate these changes
Transform Health provides policy, design, and implementation support for outreach and enrollment programming around the country:
- Policy analysis, research and design
- Program strategy and planning
- Partnership development and community engagement methodologies
- Communications strategy, marketing, and events
- Data strategy
- And more…
Contact Heather Bates, COO and Vice President, at heather@transformhc.com if you would like to work together, or book a free discovery call today.
Transform Health is an Inc. 5000-ranked national private health care consulting firm with a mission to drive systems change to build healthy communities.