Marketplace Changes

CMS finalized a rule that shortens the Marketplace open enrollment window to Nov. 1 – Dec. 15 for federally-run Marketplaces and requires that no Marketplace offer an open enrollment longer than Nov. 1 – Dec. 31; increases eligibility verification and reconciliation requirements for premium tax credits; and adjusts the methodology used to set premiums. It is estimated that some of these changes may result in lower overall premiums and will reduce improper enrollments and payment of premium tax credits. 

However, in August, a U.S. District Court Judge issued a preliminary injunction blocking several provisions which had been set to take effect shortly and would likely have affected coverage for individuals beginning in 2026. Some provisions of the rule will proceed (e.g., changes to cost-sharing calculations and the elimination of the 60-day reconciliation window for income discrepancies), but the ruling temporarily preserves broader access to Marketplace individual coverage while litigation continues over whether the rule unlawfully undermines the ACA’s protections.

In addition, expansion of the premium tax credits expires at the end of 2025. Without further legislation expanding the credits, many individuals may not qualify for premium tax credits or may qualify for lesser tax credits, making coverage in 2026 via the Marketplace less affordable.

Author