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 – Dec 15, 2026 (shortened) | Nov 1, 2027 – Dec 15, 2027 (proj.) |
| Enhanced subsidies (ARPA/IRA) | Available (final year) | Expires unless Congress acts | TBD |
| 400% FPL cliff | No cliff (8.5% cap) | Returns if subsidies lapse | TBD |
| CSR funding | Loaded onto Silver premiums | Same — Silver-loading continues | Same expected |
| Auto-reenrollment | On (with hierarchy) | On; CMS proposed tighter rules | TBD |
| Agent of Record changes | Three-way verification required (FFM) | Continued; SBE rules vary | TBD |
| HSA contribution (self / family) | $4,400 / $8,750 | $4,550 / $9,050 (est.) | Indexed |
| OOP max (non-HSA plans) | $9,200 / $18,400 | $9,500 / $19,000 (est.) | Indexed |
| DACA enrollment | Eligible (pending court rulings) | Subject to ongoing litigation | TBD |
| Short-term plan limits | 3 months + 1 renewal max | Same rule in effect | TBD |
The biggest open question is whether Congress extends the enhanced premium tax credits past 2025. If it lapses, expected contributions revert to pre-ARPA tables and the 400% cliff reappears.
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.