July 21, 2025

We want to keep you informed and prepared as we head into the 2026 open enrollment period (OEP). While the enrollment window will remain the same as last year, several important regulatory and legislative changes are on the horizon. These could impact how consumers enroll and maintain coverage.

Please review the key updates so that you may begin planning for a successful open enrollment period. 

Key Changes to the 2026 OEP:

• New Passive Enrollment Fee for $0 Plan Members: Individuals enrolled in a $0 premium plan who passively reenroll without updating their income or eligibility information may now be subject to a fee.
• Expiration of Expanded Advance Premium Tax Credit: The enhanced premium subsidies introduced under the American Rescue Plan are set to expire, which may result in higher premiums for many enrollees.
• Change to Special Enrollment Period for Those at 150 Percent of Federal Poverty Level (FPL): The special enrollment period for individuals at or below 150 percent of the FPL will no longer be available year-round.
• Auto-Reenrollment Policy Change: The Exchange will no longer automatically switch bronze members eligible for cost-share reductions to silver plans. Clients must actively select silver plans to access cost-share reductions.
• Return of Preenrollment Verifications: Applicants will once again need to verify eligibility before enrollment is finalized, adding a step to the process.