Open enrollment for Affordable Care Act (ACA) health insurance coverage is underway in most states, bringing several significant changes for shoppers. Consumers will navigate premium increases, enhanced identity verification requirements, potential broker shortages, and new subsidy restrictions.
Stricter Identity Checks and Broker Rules
The Centers for Medicare & Medicaid Services (CMS) has introduced tighter rules to prevent fraud and unauthorized enrollments on the federal marketplace, which serves 29 states. All consumers using an agent or broker must now receive a one-time confirmation code or link via text, email, or automated call to authorize them. Furthermore, individuals classified as “high-risk”—such as first-time applicants, those changing states, people working with a new agent, or policies with a monthly premium of $30 or less—must verify their identity through an approved third-party service like Experian before authorizing an agent.
Joshua Brooker, who oversees an insurance agency in Pennsylvania, told NPR that CMS likely targeted these groups because switching brokers or moving can indicate impersonation attempts, while low-premium plans are easier for bad actors to target since policyholders might never receive a bill. Brooker warned that up to one in five consumers may face extra hurdles and potentially give up on getting insured.
In addition, CMS implemented a moratorium on new brokers entering the ACA market. Agents not registered with the federal marketplace in 2026 cannot assist with 2027 enrollments until February at the earliest. CMS stated this move addresses disproportionate compliance issues among newly registered agents, noting that hundreds of non-compliant brokers were removed this year.
Jason Fine, who runs a Florida brokerage, told NPR he supports action against rogue agents switching client coverage without authorization, but criticized the short-term chaos the moratorium causes. He noted that small brokers who typically hire staff toward the end of the year cannot find available registered agents, which unintentionally benefits larger call centers that can afford year-round staffing.
Industry groups have taken legal action against the administration. The National Association of Benefits and Insurance Professionals filed a lawsuit on October 15, and Health Agents for America filed a lawsuit on October 21 seeking a temporary restraining order, arguing the moratorium unfairly targets thousands of agents wanting to sell ACA plans.
Costs, Subsidies, and Policyholder Advice
Following the expiration of enhanced subsidies at the end of 2025, overall enrollment has declined. While most consumers purchasing coverage for next year will still receive subsidies, they are less generous than before. Premiums are slated for double-digit increases for the upcoming year, averaging around 15%, driven by rising medical care costs, general inflation, and labor shortages.
Subsidies remain income-based and are cut off for households earning more than four times the federal poverty rate, which equals $63,840 for a single person, $86,560 for a couple, and $109,280 for a family of three during this enrollment cycle. Anne Petry, co-owner of Jaggi Petry Insurance & Investments in Forsyth, Illinois, told NPR that affordability remains the biggest issue, noting there will be a breaking point for people.
Additionally, the One Big Beautiful Bill Act passed by Congress last year strips subsidy eligibility from many lawfully present immigrants, including refugees, asylees, people with temporary protected status, those with pending green-card applications, and temporary H-1B visa holders. Only green-card holders, certain Cuban and Haitian immigrants, and citizens of Micronesia, the Marshall Islands, or Palau remain eligible for ACA subsidies.
Experts advise consumers not to let their plans auto-renew and to compare options online, as out-of-pocket maximum caps are also increasing by 13% to $12,000 for individuals and $24,000 for families in 2027. Stacey Pogue, a senior research fellow at Georgetown University, told NPR that consumers relying on brokers should reach out early because available appointment slots will fill up faster with fewer active agents.
