Newsletter

ACA CHANGES FOR 2025–2026: WHAT YOU NEED TO KNOW

The Affordable Care Act is undergoing significant shifts due to two major policy drivers: the Marketplace Integrity and Affordability Final Rule (referred to as "the Integrity Rule" in this article) finalized by CMS on June 20, 2025 and the One Big Beautiful Bill Act (OBBBA) signed into law on July 4, 2025. These changes will reshape eligibility, affordability, and enrollment processes for millions of Americans.

NOTE: Where “Source” is indicated below, this refers to whether the item is included in the Integrity Rule, the OBBBA, both, or neither the Integrity Rule nor the OBBBA.

We've authored this article based on the latest information available, and believe it’s as accurate as possible. We feel the changes outlined below are the major changes that will be affecting ACA-eligible individuals through 2026 (some of the changes are effective in 2025 and others are effective in 2026). Several other changes have also been included in the Integrity Rule and the OBBBA, but most of these are highly technical and difficult to explain to readers. Nevertheless, these other changes will have an impact on premium costs and benefits.

We’ll continue to provide information on ACA changes both in this newsletter and on our website.

Top ACA Changes

1. Expiration of Enhanced Premium Subsidies

• Effective: End of 2025
• Source: Neither (subsidies sunset as of 12/31/2025 and were not extended in the OBBBA)
• Impact:

• Enhanced subsidies sunset, especially affecting those over 400% of the Federal Poverty Level (FPL) who will not be eligible for subsidies starting January 1, 2026, but also affecting those whose earnings are between 100% and 400% of the FPL, who in in most cases now will be eligible for lower subsidies calculated as they were before the passage of the American Rescue Plan act in 2021).

• Up to 4.2 million people could lose coverage nationally.

• Florida has a disproportionately large share of ACA enrollees nationally, and it’s estimated that nearly two million Floridians could lose ACA coverage because they can't afford 2026 premiums.

Subsidy Calculation Table (2026) – What Enrollees Will Pay For Benchmark Silver Plans (This Table Was Effective Prior To Passage Of The American Rescue Plan Act In 2021)

2. Stricter Income Verification Requirements

• Effective: Immediate through 2026
• Source: Integrity Rule
• Impact:

• The period to verify income, if required, is 90 days; automatic 60-day extensions for those who don't verify by the 90th day will no longer be available.
• Self-attestation is no longer accepted.
• Applicants may be required to submit more robust documentation to verify income than in the past.
• Individuals cannot receive subsidies while their income is being verified. They must pay the full unsubsidized premium until required documentation is reviewed and approved.
• 75% of all new enrollments must be verified.
• A Hold Harmless Provision protects those who project income greater than 100% of the Federal Poverty Level (FPL) but who actually receive income under 100% of the FPL--only if criteria are met.

Note: We're awaiting clarification regarding exactly how the new verification process will work and will publish this both in this newsletter and on our website. Individuals should plan on applying earlier than they formerly would have and to provide any required proof of income as soon as possible before the effective date of their policy: this will minimize or eliminate any requirements to pay unsubsidized premiums by people who are otherwise eligible for tax subsidies. In addition, individuals should also plan on making binder (first month's premium) payments as soon as they are permitted to do so.

3. Annual Reverification of Tax Credit Eligibility

• Effective: Plan Year 2026
• Source: OBBBA
• Impact:

• Ends automatic re-enrollment.
• Enrollees must verify eligibility annually.
• Complements the Integrity Rule’s stricter initial verification process.

4. Removal of Repayment Caps

• Effective: Plan Year 2026
• Source: OBBBA
• Impact:

• Full repayment of excess subsidies required.
• No income-based caps.
• Hold harmless protections remain separate.
• Items 3 and 4 are listed separately from item 2 due to distinct legal origin and financial implications.

5. Shortened Open Enrollment Period

• Effective: Fall 2026 for 2027
• Source: Both
• Impact:

• November 1–December 15 (federally facilitated exchanges); maximum 9 weeks (state-based exchanges).
• All coverage must begin January 1—no February 1 start dates.

6. Elimination of Monthly Low-Income Special Enrollment Period

• Effective: September 1, 2025 through 2026
• Source: Both
• Impact:

• Monthly SEP for 100%–150% FPL paused for federally facilitated exchanges only.
• State-based exchanges may continue offering this SEP.
• Other SEPs still eligible for subsidies.

7. $5 Premium Requirement for Zero-Dollar Plans

• Effective: 2026 only
• Source: Integrity Rule
• Impact:

• Applies to federally facilitated exchanges only.
• Enrollees must pay $5/month unless and until they actively verify eligibility.

8. Removal of Automatic Silver Plan Re-enrollment

• Effective: 2026 only
• Source: Integrity Rule
• Impact:

• CSR (Cost Sharing Reduction)-eligible Bronze enrollees won’t be auto-switched to Silver Cost Sharing Reduction plans.
• Persons qualifying must actively choose Silver CSR plan to receive enhanced benefits.

9. Insurers May Require Payment of Past-Due Premiums



• Effective: Immediate
• Source: Integrity Rule
• Impact:



• Prior rule allowed collection of 1 month of past-due premiums.
• The new rule allows carriers to collect all past-due premiums, regardless of year.
• Applies if permitted by state law.
• Designed to reduce adverse selection and promote continuous coverage.

Summary Table

• HEALTH SAVING ACCOUNTS IN 2026: WHA THE OBBBA CHANGED—AND WHAT IT DIDN’T

The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, introduced several key reforms to Health Savings Accounts (HSAs), expanding access and modernizing how Americans can use these accounts. However, not all proposed provisions made it through the Senate. Here’s a breakdown of what’s changing in 2026—and what was left out.

HSA Provisions That Passed

Starting January 1, 2026, the following updates will take effect:

• Expanded Eligibility for ACA Enrollees

• Individuals enrolled in any Bronze or Catastrophic plan through an exchange (note: this does NOT apply to off-marketplace plans) will now be eligible to open and contribute to HSAs. This change significantly broadens access for millions of Americans who were previously excluded.

• Direct Primary Care (DPC) Compatibility

• HSAs can now be used to pay for DPC memberships—up to $150 per month for individuals and $300 per month for families. Importantly, having a DPC arrangement no longer disqualifies someone from contributing to an HSA.

• DPC membership is a healthcare model where patients pay a flat monthly fee directly to a primary care provider in exchange for unlimited access to routine and preventive care. It bypasses traditional insurance billing, offering a more personal and simplified experience. Services typically include:

• Annual physicals
• Sick visits
• Chronic condition management
• Basic lab work
• Telemedicine access
• Note: DPC is not insurance--it doesn’t cover hospital stays, emergency care, or specialist visits. It’s often paired with a high deductible health plan or health sharing arrangement for broader coverage.

• Permanent Telehealth Flexibility

• High-deductible health plans (HDHPs) may continue offering first-dollar coverage for telehealth services without affecting HSA eligibility. This provision, originally temporary, is now permanent.

• Updated Contribution Limits for 2026

The IRS has set the following HSA contribution limits for 2026:

• Self-only coverage: $4,400
• Family coverage: $8,750
• Catch-up contribution (age 55+): Additional $1,000

Provisions Removed by the Senate

Several House-passed HSA reforms were excluded from the final OBBBA legislation during Senate negotiations:

• Working Seniors on Medicare Part A

• The House proposed allowing working seniors enrolled in Medicare Part A to continue contributing to HSAs. This provision was removed.

• Income-Based Contribution Increases

• Proposed higher contribution limits for individuals earning under $75,000 and families earning under $150,000 were eliminated due to budgetary concerns.

• Spousal Catch-Up Contributions

• A provision allowing both spouses age 55+ to make catch-up contributions to a single HSA account was removed. Separate accounts are still required.

• FSA Compatibility

• The bill would have allowed HSA eligibility even if a spouse was enrolled in a Flexible Spending Account (FSA). This change did not pass.

• Fitness and Wellness Expenses

• Gym memberships and personal training expenses were proposed as qualified medical expenses (up to $500/year). This provision was excluded.

• Retroactive Expense Reimbursement

• The House proposed allowing HSA funds to cover medical expenses incurred up to 60 days before the account was established. This was removed from the final bill.

What This Means For Consumers



The OBBBA marks the most significant expansion of HSA access in nearly two decades. ACA on-exchange enrollees, telehealth users, and those in Direct Primary Care arrangements will benefit most from the new rules. However, the removal of provisions aimed at working seniors and lower-income families underscores ongoing limitations in HSA policy.

As we approach the 2026 enrollment season, it’s essential to understand these changes. HSAs remain a powerful tool for managing healthcare costs—but understanding the fine print is key to maximizing their value.

ACA PREMIUMS EXPECTED TO JUMP IN 2026

According to a preliminary analysis published by the Kaiser Family Foundation on July 18 of rate filings submitted by over 100 ACA insurers to state regulators to justify premium changes for 2026, marketplace insurers are proposing the sharpest premium hikes in over five years—a median increase of 15% for 2026, with some consumers facing out-of-pocket jumps as high as 75% or even more.

Finalized 2026 rate changes are expected to be published in late summer, and individuals will be able to see how their plan’s premium is changing shortly before open enrollment starts November 1. Note: the analysis looks at insurers from 19 states and the District of Columbia but does not include California or Florida.

Several factors are fueling the surge:

• Enhanced premium tax credits that make coverage more affordable (see first article) will expire at the end of 2025. This is expected to drive up out-of-pocket premium payments 75% or more for some individuals. The vast majority of insurers are mentioning this factor in their rate filings, with most saying they’ll raise premiums by an additional 4% to account for elimination of the enhanced credits.

• New integrity and affordablity regulations are introducing eligibility challenges and administrative strain (see first article).

• Tariffs could drive up the cost of some drugs, medical equipment, and supplies. This is driving rate increases about 3% higher than they otherwise would be.

• Labor costs and staff shortages are pushing provider reimbursements up.

The cost of healthcare services like hospitalizations and physician care, as well as prescription drug costs (referred to as “medical trend”) is usually the primary driver of premiums.

For 2026, most insurers say medical trend is similar to last year’s reported 8%. However, the changes outlined in the above bullets account for almost half of the rate increases.

What You Should Expect For 2026 Plans

Expect both individual and employer-sponsored plans to feel the impact of increased premiums. To avoid surprises, review your options closely during open enrollment and seek advice on cost-saving strategies. 

We anticipate lower-cost alternative plans to be introduced before the end of the year. It's also possible the Administration will liberalize regulations that will permit longer short-term and other plans to be available. We're evaluating what alternative plans we can add to our portfolio that may be available to alleviate the increased cost pressure. We'll include more information on 2026 rate increases and benefit alternatives as soon as additional information becomes available.

About Paul Cholak

Paul has over forty years of benefits experience and has been Director of Employee Benefits for large companies, as well as a benefits consultant with major consulting firms. He understands the health and life insurance needs of individuals and families of all ages. He also has considerable experience in selling health and life insurance to employer groups.

He guides you through the steps of getting health and/or life insurance and is available to help you both BEFORE and AFTER you've made your purchase decision.