Open Enrollment for ACA Health Insurance: Key Changes for 2027

As open enrollment for Affordable Care Act (ACA) health insurance begins for 2027, participants will face premium hikes and new identity verification procedures.

The enrollment period kicks off on November 1 in most states, though some have started earlier. This year, participants will notice changes driven by both market dynamics and regulatory shifts, including the expiration of enhanced subsidies that ended in 2025. This subsidy lapse has already caused coverage disruptions for many, with policy analysts pointing to over 760,000 policy cancellations associated with fraudulent enrollments. The Centers for Medicare & Medicaid Services (CMS) have countered by implementing stricter oversight measures.

More Rigorous Identity Verification

New identity verification steps apply to consumers using agents or brokers in the federal marketplace, across 29 states. CMS has mandated that these consumers receive unique verification codes to authorize agent actions, a move aimed at curbing enrollment fraud. This does not extend to state exchanges, which opt for individual measures. High-risk applicants, identified by changes like relocating or selecting a new agent, must confirm their identities through third-party verification.

Brokers Face Temporary Restrictions

The CMS has also introduced a moratorium affecting brokers new to ACA plan registrations. Brokers who failed to register by 2026 cannot assist with enrollments until February the following year, addressing compliance issues with agents onboarded in 2026. This restriction has received varied reactions, creating hurdles for smaller agencies while potentially benefiting larger operations. Upset by the changes, some agent representative groups have launched legal action, alleging that these restrictions detrimentally impact thousands of agents.

Agent/Broker StatusRegistration DeadlineEligibility for Enrollment
Previously RegisteredBefore 2026Eligible Immediately
Newly RegisteredPost-2026 DeadlineEligible After February 2027

Subsidies and Premium Concerns

The expiry of enhanced subsidies has led insurers to propose double-digit premium increases, influencing both affordability and enrollment numbers. Despite this, most current ACA policyholders can still access financial assistance, though these offerings are less robust than before. Subsidies continue to be tied to benchmark silver-tier plan premiums and are expected to moderate premium increases to some extent.

For agents, the main challenge lies in assisting consumers amid these changes. Legislative updates now limit subsidy access for certain immigrant groups, excluding those on temporary visas. Given these evolving variables, agents strongly advise consumers to investigate market options instead of auto-renewing their plans, as changes in premiums, deductibles, and provider networks could impact plan suitability.