Year-over-year
ACA marketplace changes: 2026 → 2027 → 2028
A side-by-side of the rules brokers and consumers care about across plan years. 2028 entries are placeholders pending CMS final rules and Congressional action.
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| Topic | PY 2026 | PY 2027 | PY 2028 |
|---|---|---|---|
| Federal OEP window | Nov 1, 2025 – Jan 15, 2026 | Nov 1, 2026 – Jan 15, 2027 (shortened-OEP rule vacated June 2026) *NEW 2027 | TBD |
| Enhanced subsidies (ARPA/IRA) | Expired after 2025 | Not extended *NEW 2027 | TBD |
| 400% FPL cliff | Cliff returned (2.10%–9.96%) | Cliff applies; 2.15%–10.22% of income (Rev. Proc. 2026-26) *NEW 2027 | TBD |
| CSR funding | Loaded onto Silver premiums | Same — Silver-loading continues *NEW 2027 | Same expected |
| Auto-reenrollment | On (with hierarchy) | On; CMS proposed tighter rules *NEW 2027 | TBD |
| Agent of Record changes | Three-way verification required (FFM) | Continued; SBE rules vary *NEW 2027 | TBD |
| HSA contribution (self / family) | $4,400 / $8,750 | $4,500 / $9,000 (Rev. Proc. 2026-24) *NEW 2027 | Indexed |
| OOP max (non-HSA plans) | $10,600 / $21,200 | $12,000 / $24,000 (CMS) *NEW 2027 | Indexed |
| DACA enrollment | Eligible (pending court rulings) | Only certain immigration statuses qualify for APTC from Jan 1, 2027 *NEW 2027 | TBD |
| Short-term plan limits | 3 months + 1 renewal max | Same rule in effect *NEW 2027 | TBD |
The enhanced premium tax credits were not extended. For 2027 the 400% FPL cliff applies, expected contributions run 2.15%–10.22% of income, and the max out-of-pocket rises to $12,000 / $24,000. Open Enrollment runs Nov 1, 2026 – Jan 15, 2027 in HealthCare.gov states.
The information contained on this website is for educational purposes only. We are not responsible for missing or inaccurate information. Please consult a licensed insurance broker in your state and area for insurance advice. Please consult a CPA for tax or legal advice.