ACA Changes for Plan Year 2026

ACA Changes for Plan Year 2026 – What This Means for Enrollees

Premium Increases Looming Large

In this post, we will go over some of the ACA changes for plan year 2026. The first one being; a median premium increase. Nationwide across ACA Marketplace plans, insurers have proposed median premium increases of around 18–20% for 2026; about double the rate change seen in 2025.

Enhanced Tax Subsidies Expire

The enhanced premium tax credits, a key feature under the American Rescue Plan and later extensions, could expire at the end of 2025, unless Congress acts. Their expiration may trigger both premium and enrollment shifts:

Over 75% increase in net premiums for many enrollees. Gross premiums also projected to climb, due to a less healthy remaining risk pool as healthier individuals opt out

Enrollment Process & Verification Tightened

Several regulatory changes taking effect in 2025 will reshape how people enroll in 2026 plans:

• Maximum out-of-pocket limits will rise: individual limit is $10,600 for 2026 and $21,200 for families.
• $5 monthly premium for auto-renewed $0 premium plans, unless eligibility is actively reconfirmed
• Auto-renewal from Bronze to Silver (for CSR-eligible individuals) is no longer allowed; this could lead to missed subsidies without active action
• SEP (Special Enrollment Period) applicants now face pre-enrollment eligibility verification in HealthCare.gov states—covering at least 75% of new enrollments; changes are temporary for 2026
• Monthly enrollment windows for low-income people, introduced under Biden, will be discontinued, and the open enrollment period will be shortened by a month

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HSA Eligibility Expanded

• Starting in 2026, Bronze and Catastrophic Marketplace plans become HSA-eligible, high-deductible health plans (HDHPs). Additionally, direct primary care (DPC) membership won’t disqualify HSA contributions, and DPC fees become qualified medical expenses
• This provides greater tax-advantaged savings options and can help lower Modified Adjusted Gross Income (MAGI) to potentially retain subsidy eligibility

“One Big Beautiful Bill Act” & Medicaid Cuts

• The sweeping One Big Beautiful Bill Act (H.R.1) introduces:
  • $1.2 trillion in cuts to Medicaid and ACA subsidies, paired with stricter eligibility and verification requirements
  • Medicaid work requirements (80 hours per month), more frequent eligibility checks, reduced provider taxes, and limits on Medicaid for green card holders and immigrants
  • The CBO estimates up to 10 million will lose Medicaid, 2 million ACA coverage, and others become uninsured
  • The legislation also includes expansions like a Rural Hospital Fund, but critics say many will face access barriers

Reduction of Gender-Affirming Care & Legal Challenges

• The Trump administration’s proposed rule would remove gender-affirming care as an essential health benefit for ACA plans starting in 2026
• Other rules allowing insurers to deny new coverage if past premiums are unpaid, stricter income verification, and other barriers may cause 725,000 to 1.8 million people to lose coverage
• Mayors and doctor groups are suing, arguing these changes undermine ACA’s purpose; litigation is ongoing

Summary Table: What 2026 Holds for ACA

The 2026 ACA landscape is shifting dramatically. With rising costs, tighter eligibility, and policy rollbacks, coverage is becoming more complex and costly for many Americans. While expanded HSA access and some protections (like the Rural Hospital Fund) offer benefits, they don’t offset affordability challenges.

Agents, stay up-to-date on the our latest webinars an agent events.

For consumers:

• Actively confirm eligibility during open enrollment—not auto-renew.
• Explore HSA-compatible options (like Bronze plans) to reduce taxable income and manage costs.
• Keep an eye on subsidy extensions; Congressional action could mitigate higher premiums.

For policymakers and advocates:

• Continuing subsidies and preserving access remain critical to maintaining ACA’s promise.
• Legal and policy responses to rollback rules (e.g., gender-affirming exclusions) could reshape outcomes before 2026.