The ACA marketplace open enrollment period began Nov. 1, with consumers facing higher average premiums, fewer plan options in some states and new regulatory scrutiny.
Seven notes:
- Finalized benchmark silver premiums for 2027 are up by an average of 13%, according to KFF, marking the second consecutive year of double-digit premium hikes (benchmark premiums rose 26% from 2025 to 2026). Insurers have largely pointed to rising underlying care costs, the expiration of enhanced premium tax credits at the end of 2025 and a deteriorating risk pool, which is expected to continue worsening as healthier enrollees drop coverage next year.
- Individual market enrollment dropped 18% from June 2025 to June 2026, a loss of more than 4.6 million, to 20.5 million enrollees, according to KFF. The Congressional Budget Office has projected marketplace enrollment will fall from a peak of 22.4 million in 2025 to 13.1 million in 2027.
- Insurer market exits outpaced new entrants into the market for 2027, with 12 insurers announcing they will stop offering plans on the exchange nationally or in specific states. Notably, Cigna is exiting the market entirely (11 states), and Molina is cutting from 14 states to six. Among the seven market entrants, Oscar will be available on the South Carolina marketplace, AmeriHealth Caritas will be in Indiana and Ohio, and CalOptima Health will offer plans on the California marketplace. Some major insurers are expanding and contracting simultaneously across different states.
- Ahead of open enrollment, CMS urged insurers to have their agents and brokers record consumer calls involving plan selection, enrollment, sales and marketing. The agency also recommended insurers evaluate enrollment records on roughly a monthly basis and take action against noncompliant agents within one month. Separately, CMS has paused new broker registrations on the federal exchange through February 2027, which, combined with cuts to ACA navigator funding, could reduce enrollment assistance available to consumers.
- In late October, a group of Senate Democrats sent letters to 10 of the largest marketplace insurers, accusing them of “quietly colluding” with the Trump administration to terminate coverage for more than 760,000 people. CMS canceled roughly 315,000 plan year 2026 policies retroactive to Aug. 31, saying the enrollments were unauthorized and enrolled through brokers without verified documentation. The senators allege the process did not follow established rules governing mid-year eligibility redeterminations and that CMS did not update federal exchange enrollment rules to reflect the process until Oct. 1, more than a month after the terminations were carried out.
- Several states that run their own exchanges are using state-funded subsidies to offset the loss of the enhanced premium tax credits. New Mexico fully backfilled the expanded credits in 2026 and is continuing the program into 2027.
- Some ACA eligibility restrictions for lawfully present immigrants are already in effect under HR 1, and broader ones take hold in January. Starting next year, the law will limit premium tax credit eligibility for certain groups of lawfully present immigrants, including refugees and asylees. It will also prevent individuals who lose Medicaid coverage for not meeting work requirements from receiving subsidized marketplace plans. Additionally, limits on repayment of excess premium tax credits have been eliminated, meaning enrollees whose incomes end up higher than projected could face larger-than-expected tax bills. Separately, litigation has paused the implementation of several marketplace rule changes, including income verification requirements and an expansion of catastrophic plan eligibility.
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