Navigating the annual Affordable Care Act Marketplace open enrollment season can be a bit like driving down a road that seems familiar but winds up having unexpected twists and turns. KFF has provided a roadmap to 10 things that brokers should watch for this year.

1. Unsubsidized premiums are increasing modestly, but most enrollees won’t pay them. Premiums for benchmark silver plans, which are the basis, are increasing by 4% on average, while the lowest-cost bronze premiums are up by 5%. However, the vast majority (92%) of Marketplace shoppers receive a subsidy, and with enhanced subsidies, most of them can find a plan with a premium of less than $10 per month.
2. This could be the last year of enhanced subsidies. Enhanced subsidies under the Inflation Reduction Act are set to expire at the end of 2025. If so, the original ACA subsidies will remain in place, but premium payments (net of subsidies) are expected to double or more in a number of states in 2026.
3. Marketplace shoppers will have more choice of insurers. On average across states, 9.6 insurers are participating on the ACA Marketplaces, which is higher than in any previous year.
4. Open enrollment continues until January 15 in most states. The exception are Idaho (December 16), Massachusetts (January 23) and California, New Jersey, New York, Rhode Island and the District of Columbia (all January 31).
5. New states are transitioning to a state-based Marketplace. Georgia will be transitioning to a state-based Marketplace for the 2025 plan year, which will bring the total number of states to 20.
6. The federal government is taking new actions to combat fraud. The government has suspended certain brokers and has applied Healthcare.gov standards on web brokers and direct enrollment entities to state-based Marketplaces.
7. Changes to short-term plans are taking effect. The new rules require that short-term plans be limited to four months total and come with a consumer notice in all online and written marketing, enrollment application and other materials stating that the coverage “is NOT comprehensive health coverage.”
8. Special enrollment opportunities are changing. HealthCare.gov enrollees with incomes up to 150% of the federal poverty line will continue to have a year-round special enrollment opportunity, although this is optional for state-based Marketplaces.
9. Deferred Action for Childhood Arrivals recipients will be allowed to sign up for subsidized coverage through the Marketplace in 2025. DACA recipients are allowed to sign up for coverage through the Marketplace or the Basic Health Program. They will have access to premium tax credits and cost sharing reductions, even if their income is below 100% of the federal poverty line.
10. Network adequacy rules must be met. Starting in 2025, federal Marketplace plans will be required to meet maximum appointment wait-time standards, including no more than a 10-business day wait for a behavioral health appointment, a 15-business day wait for routine primary care appointments and 30 business days for non-urgent specialty care appointments.

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