Newsletter

ENROLL BY DECEMBER 15 IF YOU WANT AN ACA PLAN WITH A JANUARY 1, 2026 EFFECTIVE DATE

Open Enrollment for Affordable Care Act plans runs through January 15, 2026. However, you must enroll by December 15 if you want an ACA plan with an effective date of January 1. If you’re enrolling for an ACA plan for the first time or changing carriers (as well as in certain other circumstances), you must also make a binder payment (i.e., advance payment of the January premium) before January 1 as well.

If you enroll in an ACA plan between December 16 and January 15, your enrollment date for an ACA plan will be February 1. Any required binder payment must be made before that date.

If you enroll for one of the Association plans, you must enroll by December 20 if you want a January 1 effective date. If you are considering a short-term plan you should plan on enrolling and paying your first month’s premium by December 22 if you want to avoid the seven-day waiting period for sickness and desire a January 1 effective date.

STATUS OF ENHANCED TAX SUBSIDIES

The enhanced tax subsidies that were enacted in 2021 sunset as of December 31 and are not reflected in tax subsidies being calculated for 2026 plans.

One of the Democrats’ major objectives during the recent government shutdown was to extend those tax subsidies beyond this year. However, this was not accomplished. The Republicans agreed to have a vote in December on extending tax subsidies, but it is very doubtful that any extension of tax subsidies affecting 2026 ACA plans will occur.

President Trump has set a target date of January 30 for Republicans to pass legislation to change the Affordable Care Act. If legislation does pass it’s doubtful that anything realistically could be done to extend tax subsidies for 2026. The reason is that there would need to be extensive reprogramming and adjustment of premiums, and it doesn't seem practical to assume this could occur before 2027 open enrollment.

President Trump has been quoted as desiring that the amounts currently paid by the government to ACA insurance carriers be paid directly to insured individuals instead. This approach does not appear to be feasible because it ignores risk sharing and other features that would disappear if payment were made in such manner.

The bottom line is that we doubt any change to current law can be made in time to affect 2026 plans. We do expect to see liberalized regulations that will additional permit alternative non-ACA approaches to be introduced during the coming year. 

LESSONS LEARNED SO FAR REGARDING 2026 ACA OPEN ENROLLMENT

The Affordable Care Act (ACA) Marketplace enrollment for 2026 is underway, and this year brings significant changes that could affect your coverage and costs. No information is yet available concerning how many people have enrolled in ACA plans and how enrollment figures for 2026 differ from prior years.

Here’s an analysis to help you make confident decisions.

Premiums Are Higher This Year

• Many insurers have raised premiums for 2026.

• If you don’t review your alternatives and act before automatic enrollment provisions take effect on December 15, you might be auto enrolled into a more expensive option than you would have selected had you reviewed options beforehand.

Tax Subsidies (Advanced Premium Tax Credits)

• The extra financial help (enhanced subsidies) that made coverage more affordable during the pandemic ended as of December 31.

• Some middle-income families may no longer qualify for subsidies.

• Lower-income households still receive assistance, but the amount is smaller than last year.

Catastrophic and Bronze Plan Changes

• Eligibility for catastrophic plans (these are lower priced plans that include coverage for only three office visits and are not eligible for subsidies) has been broadened. However, only a few carriers are making catastrophic coverages available, and there are significant differences in availability by zip code, even in the same county.

• Individuals choosing catastrophic or bronze plans are permitted to establish health savings accounts, which can provide significant tax savings.

 What Means for You

• Premiums may be higher than you expect.

• Failing to update your Marketplace information could mean losing financial assistance. If you received subsidies in 2023 or 2024 and haven’t reconciled against your actual earnings for at least one year, you could lose your eligibility for a subsidy.

• Younger and healthier individuals may drop coverage, which could drive costs up further.

Steps to Take Now

• Update your Marketplace information (income, household size, contact details).

• Compare plans carefully to make sure you’re getting the best value.

• Make sure you've filed and reconciled earnings for 2023 or 2024 as a minimum.



• Act before January 15, 2026 to avoid gaps in coverage.

Bottom Line

The 2026 ACA enrollment season is different: premiums are higher and subsidies have either been eliminated or are lower than what they would have been had the enhanced subsidies enacted in 2025 been extended. By reviewing your options now and enrolling before the deadline, you can protect your coverage and manage your costs with confidence.

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.