Consumers who buy Affordable Care Act health insurance are going to see changes both big and small as open enrollment for 2027 coverage kicks off. These include premium increases, possible additional identity checks, potential delays in working with a broker and new limits on which immigrants can get subsidies.
Shoppers need to plan accordingly.
Open enrollment starts Nov. 1 in most states. Idaho, Connecticut, and Massachusetts started earlier, and some states have been allowing "window shopping" to check premium rates.
A continued decline in overall enrollment is expected, mainly because of the expiration of enhanced subsidies at the end of 2025. Policy experts say the end of those subsidies led millions to drop or lose coverage through the first few months of this year.
But the Trump administration sees victory in the falling enrollment, crediting its various efforts to reduce fraud, including the August cancellation of policies covering 760,000 enrollees suspected to be improperly signed up. A small number of those enrollees have regained coverage.
Have your ID ready
One of the biggest changes for people shopping for their 2027 coverage will be increased scrutiny of both consumers and agents. The requirements are aimed at thwarting fraud or improper enrollments. For consumers, it could slow the enrollment process.
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The new rules, outlined by the Centers for Medicare & Medicaid Services, affect only consumers using agents or brokers to help them enroll through the federal marketplace, which serves 29 states. They do not apply to state-based exchanges, which have their own rules and have in most cases been more successful at preventing fraudulent sign-ups.
For starters, all consumers using an agent in the federal marketplace will need to get a one-time confirmation code or link to authorize a specific agent to enroll them or make changes on their behalf. It will be sent to consumers by text message, email or an automated phone call from one of the private enrollment platforms used by their agent. Returning consumers who have incorrect or outdated contact information will first need to call the federal marketplace themselves or submit an application online to update it.
Additionally, consumers and policyholders deemed "high-risk" must verify their own identity before authorizing an agent. CMS defines as "high-risk" first-time applicants or those with existing coverage whose applications involve a change of state, as well as consumers working with a new or different agent or with a monthly premium payment of $30 or less.
Joshua Brooker, who oversees an insurance agency in Pennsylvania, said CMS appears to have selected people in those groups for greater scrutiny because "someone who is moving to a new state or switching brokers — that could be a broker trying to impersonate a consumer."
The $30-a-month cutoff may be tied to concerns that plans with no or low monthly premiums are easier for bad agents to target for unauthorized enrollments because the policyholder may never get a bill. Some rogue agents even pay the low monthly amount themselves and still make a profit from the commission, Brooker said.
The broad nature of the new rules, though, has Brooker concerned "that up to 1 in 5 consumers is going to have to do extra identity proofing" and may just give up and not get insured.
Consumers designated high-risk must prove their identity through a CMS-approved third party such as credit company Experian, which generally asks questions only the consumer should be able to answer. People who fail this test may be asked to call Experian's help desk or submit their applications themselves by creating a healthcare.gov account, which requires them to upload identification such as a driver's license, a 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 might "be an appropriate response by CMS that targets fraudulent enrollments but might also create extra hurdles."
There may be fewer brokers
CMS in September issued a rule that places a moratorium on brokers new to offering ACA coverage. Agents not registered with the federal marketplace in 2026 will not be allowed to assist with enrollments for 2027 until February at the earliest, past the end of open enrollment season.
CMS said it took this step because a disproportionate number of "significant compliance concerns" in 2026 came from newly registered agents or brokers. Additionally, the agency has kicked out "hundreds of non-compliant agents and brokers" this year.
Jason Fine, who runs a brokerage in Florida, said he agrees with the concept behind these changes. He has reported multiple times to CMS, for instance, that rogue agents have switched his clients' coverage without authorization, wanting the agency to take action against them. But he said the updated rules also raise 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."
That's because the moratorium will make it much harder for small brokers to help clients this year. His agency and others often pare their staffing after open enrollment but hire again toward the end of the year. He was planning to add up to 10 agents to his core staff of about five but has been told by recruiters that he's unlikely to be able to find anyone who was registered for 2026 and is still available.
He suggested that the move unintentionally benefits larger call centers, some of which were doing much of the marketing that regulators feared led to unauthorized switching. Call centers often maintain larger staffs.
"They can afford to keep a staff of 25 or 40 people all year long," Fine said.
Groups representing agents are very unhappy with the directive. One, the National Association of Benefits and Insurance Professionals, filed a lawsuit on Oct. 15 against the Trump administration over the moratorium, saying it unfairly targets 19,000 agents who may want to sell ACA plans for 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 sales agent group, which on Oct. 21 filed suit seeking a temporary restraining order on the moratorium. "All these agencies who have trained new agents and paid thousands of dollars now have people who won't be able to work."
It all leads to an important piece of advice from Georgetown's Pogue: Consumers should not delay making 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 continue to be an issue
This year, after Congress did not renew the expiring enhanced subsidies, most people getting ACA coverage saw what they had to pay increase. Higher earners lost subsidies entirely. Add in double-digit premium increases, and most people had to pay substantially more for their coverage.
Still, most people who buy ACA coverage for next year will receive a subsidy. It will just be less generous than it was before the enhancements expired at the end of 2025.
The subsidies are pegged to the premium costs of benchmark plans, the name given to the second-lowest-priced silver-tier plan in an area.
This 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 there are other factors at work, too.
Last year's average premium increase of 26% was the largest in years. It was driven in part by insurers' fear that the expiration of subsidies would cause healthier people to drop out of the marketplace. Other drivers often cited for such increases include a rise in overall medical care costs and general inflation, and labor shortages.
For the upcoming year, those dynamics remain a concern, with premiums slated for double-digit increases, although at 15%, slightly lower than last year.
Subsidies are income-based and cut off for households earning more than four times the federal poverty rate. During this open enrollment season, that amount is $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, with her father, owns Jaggi Petry Insurance & Investments in Forsyth, Illinois, and helps customers purchase health insurance, including ACA plans. "There definitely will come a breaking point for people."
Agents and other experts say consumers should not allow their plans to automatically renew and should instead go online to compare premiums and coverage, which can change each year even for the same plan. There may be less expensive alternatives, including plans from new insurers, so they suggest looking at not just 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.
"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 said it is important to check options because the cap on out-of-pocket maximums for ACA plans is also increasing.
That amount, which represents the most a consumer must pay toward deductibles, copayments and coinsurance before the policy is expected to cover remaining in-network medical costs, was $10,600 for an individual and $21,200 for a family plan this year. In 2027, it will grow by 13% to $12,000 for an individual and $24,000 for family coverage. Lower caps on out-of-pocket maximums are set for households earning up to 2.5 times the federal poverty level.
The One Big Beautiful Bill Act, which Congress passed last year, also strips subsidy eligibility from many lawfully present immigrants, including people holding temporary H-1B work visas, refugees, asylees, people with temporary protected status, and those with pending green-card applications.
Three immigrant groups can still get ACA subsidies: green-card holders, who have permanent legal status; certain Cuban and Haitian immigrants; and citizens of Micronesia, the Marshall Islands or Palau.
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