Part 1: Private Insurance Changes
I’ve had more than one person tell me they don’t understand the One Big Beautiful Bill Act (OBBBA). And I can’t blame them. Right there in the name is the idea that’s a big bill. But they come to me for answers and that what’s I’m here for!
In today’s Straight Talk, I’m going to tell you what is in the OBBBA, when the changes happen and what we know about how that will look. Sound good? Okay, let’s do it.
From now through 2026
Let’s all remember that the OBBBA, which passed in July, is a very large piece of legislation and it touches many, many different topics. For this analysis, I’m only going to talk about the changes targeting the individual private insurance market. We will discuss the Medicaid and Medicare changes in future editions. I am in the healthcare insurance business after all, and those are the parts of the act I know about.
The first changes you might notice have already happened.
Over the past 10 years or so, different presidential administrations have taken different approaches to how health insurance marketplaces are managed. Especially how Advanced Premium Tax Credits (that’s those HealthCare.gov subsidies) are handed out, how eligibility is determined AND how enrollment works outside of the annual open enrollment period. So let’s start there.
Special enrollments
First, from 2020-2024, if you needed to buy health insurance on a state or federal exchange outside the Open Enrollment Period, you had to use what is called a special enrollment trigger. For those years, the triggers were not strongly enforced, and applicants were allowed to attest (like promise and cross their heart) that their special circumstance was actually happening. Prior to that, you had to provide some sort of written proof if you had a baby, got married, lost your coverage at work, moved or had some other life change that qualified you for special enrollment.
Starting in about April 2025, written proof is required to enroll in a HealthCare.gov plan outside of annual open enrollment. Plus, the OBBBA says you get $0 tax credits until AFTER your proof is processed and accepted by HealthCare.gov. So we are back to the original ACA rules for special enrollment outside of the annual Open Enrollment Period.
A nationwide special enrollment period for low-income individuals (people whose incomes fall between 100 to 150% of Federal Poverty Level) that was based STRICTLY on their income and allowed them to draw massive tax credits has also ended. While lower-income individuals can still qualify for special enrollment if they lose coverage or have another qualifying event, they need to submit proof as outlined, too.
Subsidies
And speaking of tax credits, the amount you are eligible for has, historically, been estimated by telling HealthCare.gov how much money you expected to make in the next year or so. If you missed above or below that threshold, the IRS would issue a correction when the person filed their federal taxes. You might owe the government money or get a bigger refund.
If you owed money, HealthCare.gov put caps on how much you had to pay back, ranging from $400 to $1,500 depending on the income reported. It is entirely possible for a low-income person to draw down $7,000 or $8,000 per year in tax credits, so limiting that damage to $400-$1,500 was important protection for low-income folks.
That’s gone. The OBBBA has stripped all safe harbors from the payback. Now, folks will get assessed exactly what they owe on their taxes without regard to their ability to pay. I’m telling you now, if you are not 100% absolutely sure you’re going to make more than 100% of FPL in income next year, DON’T accept any tax credits! The payback to the IRS could be devastating.
Oh, and speaking of the IRS, currently folks receiving premium tax credits to help pay for their HealthCare.gov plans are required to file income taxes no less than every other year. Starting at the end of this year (your 2025 filing), all people receiving tax credits MUST file taxes EVERY year. No exceptions. Every year.
Currently, a certain percentage of the population on HealthCare.gov is allowed to auto-enroll each year and keep their current plan without updating their income or eligibility information. This is also going away. Starting with this year’s Open Enrollment Period that begins Nov. 1, anyone who doesn’t update their data annually will be assessed a $5 premium charge, even on plans that are $0 premium plans. Important to keep up!
So, that’s a lot of changes in the individual marketplace! Is that it?
Nope.
Eligibility
Folks who previously qualified for tax credits but were not lawfully present citizens of the U.S. (think DACA for example) will lose their eligibility for federal payments for 2026, meaning they will be exposed to the full premium of their plans if they keep them.
Open Enrollment Period
And for next year, the 2026 Open Enrollment Period for 2027 coverage will be shorter than the past few years, only lasting from Nov. 1.until Dec. 15, 2026. In recent years, the Open Enrollment Period has extended into mid-January. This means if you are buying coverage next fall for 2027, you will need to move fast and smart! Set yourself a reminder right now.
Bronze plans
On the positive side, the OBBBA states that individuals who buy Bronze plans, or catastrophic plans, on HealthCare.gov may treat those plans as High Deductible Health Plans for tax reasons. And that makes them Health Savings Account (HSA) eligible!
Those health savings account dollars also have a new purpose for 2025 and beyond. If you would like: you can use up to $150/month (single) or $300/month (family) of your HSA money to purchase direct primary care or concierge care memberships starting on Jan. 1, 2026.
The Straight Talk is, we are just getting started on the OBBBA! Lots of changes for the folks purchasing individual coverage via HealthCare.gov. The main thing is, STAY COVERED! Few of us can afford to self-insure when it comes to healthcare. I sure can’t! (Want to read the rule yourself? It’s linked in this press release from CMS.)
And don’t forget – you don’t have to go this alone. You can work with a licensed agent with lots of HealthCare.gov experience at no cost. An agent can walk you through your 2026 plan choices and help you figure out how much financial aid, if any, you qualify for. Connect with one by calling 1-844-GET-BLUE (1-844-438-2583; TTY 711). There is no obligation to buy just for speaking to an agent.
Leave a Reply