by Heather Korbulic, VP, Policy and Communications
The health coverage landscape is shifting yet again, and the stakes for Plan Year 2026 are considerably high. With major federal changes, expiring subsidies, and new low-cost options on the horizon, health coverage will work differently for many in 2026. Agencies, consumers, and program partners alike need clarity on these changes – so the policy experts at GetInsured have compiled an overview of major policy updates, their likely impacts, and what legislation agencies should keep an eye on as we head into the future.
Recent Policy Updates
Several major policy changes are set to impact Marketplace costs and coverage in the coming year, including:
- Enhanced Subsidy Expiration: If Congress does not extend enhanced subsidies, which are set to expire at the end of the year, financial assistance for households over 400% of the federal poverty level (FPL) will end, and those under 400% will see reduced support. This would mean higher net premiums for consumers across the board, starting January 1, 2026.
- Marketplace Integrity and Affordability Rule (MIA): The MIA rule – while intended to standardize Marketplace operations – reduces state flexibility, increases administrative requirements, and presents significant implementation complexity.
The rule sought to tighten Marketplace standards with stricter broker rules, premium and actuarial value changes, a shorter Open Enrollment Period (OEP) for Plan Year 2027, stricter income and Special Enrollment Period (SEP) verification, paused low-income SEPs, and an end to DACA (Deferred Action for Childhood Arrivals) eligibility and gender-affirming care as essential benefits, among other changes.
A federal court has issued a nationwide injunction against several provisions of the MIA rule in the City of Columbus v. Kennedy.
- H.R.1 (One Big Beautiful Bill Act) Changes: From eliminating caps on advance premium tax credit (APTC) repayment and narrowing immigrant eligibility to putting restrictions on Marketplace tax credits for individuals denied Medicaid and ending automatic reenrollment for future years, this legislation reshapes affordability and access in profound ways.
- New Coverage Rules: As a result of these changes, adjustments to coverage include higher maximum out-of-pocket (MOOP) limits (+15%), narrower eligibility rules, stricter premium payment requirements, and new restrictions tied to the reconciliation of tax credits.
Although many of these policy changes apply to all states, state-based exchanges have more flexibility with regard to some changes than states operating through the Federally Facilitated Marketplace.
Why These Changes Matter and What They Require
For many consumers, these shifts will translate into confusion and financial pressure. Expiring subsidies will make coverage more expensive just as carriers propose significant rate hikes. Meanwhile, new rules around eligibility and tax filing could mean some households and individuals lose assistance altogether. Without clear guidance on how to navigate these changes, families could face surprise bills or losses in coverage.
In this environment of uncertainty, state-based exchanges have an important role to play. Many state-based exchanges have built a reputation as a trusted resource for consumers – maintaining this trust is critical now, as consumers will look to exchanges to make sense of policy changes, and many will need increased assistance to navigate their eligibility journey and plan options with confidence. Safeguarding consumer trust will require attention to both communication and resources, including:
- Updating systems to reflect changes and offer helpful information and tips.
- Communicating regularly with consumers about changes and related action steps.
- Ensuring staff have the training, resources, and capacity to provide support.
- Connecting consumers to free, local help through agents and assisters whenever possible.
The Importance of Consumer Messaging for the Open Enrollment Period: Because the 2026 OEP will be impacted by many of these changes, consumer communication is especially critical leading up to and during this period. Special Enrollment Periods will not be as accessible in 2026, so consumers need to hear a simple, repeated call to action for the upcoming OEP: SHOP TODAY. Highlighting routes to free enrollment assistance and state-specific affordability plans will also be key in this time frame.
What to Watch for in the Future
As agencies prepare for the upcoming enrollment season, ongoing attention to the following potential developments will also be key:
- Congressional Action: If Congress extends or alters enhanced premium tax credits, timing will be everything. Extensions before renewals may smooth transitions, while delays could cause major consumer confusion.
- Legal Challenges: With the challenges to the MIA rule in California v. Kennedy and City of Columbus v. Kennedy, as well as the related federal court injunction, a temporary pause on certain MIA change requirements has been granted. The final outcomes of these cases could reshape the rule.
- Medicaid Community Engagement (Work) Requirements (2027): While not immediate, these looming requirements could push more consumers toward the Marketplace, intensifying the need for streamlined enrollment.
- Closing Thought: An Opportunity to Build Trust
Market uncertainty often brings disruption, but it can also bring opportunity. By providing straightforward guidance and promoting affordable options, exchanges can not only maintain consumer trust but also strengthen it in the face of upcoming changes. At GetInsured, our product and project teams have been working hard to make sure our state-based exchange solution is ready to support not only recent policy changes – but also the communication and consumer assistance needed to preserve and strengthen trust over the coming year.
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