Following three consecutive years of record enrollment numbers, the upcoming 12th annual Affordable Care Act (ACA) Marketplace open enrollment season presents another chance for many to obtain health coverage. Additionally, it provides an opportunity for current enrollees to modify their health plans. Below are ten essential points to understand about the 2025 open enrollment period.
- Unsubsidized premiums are rising slightly, but most enrollees won’t shoulder the cost. Benchmark silver plan premiums, which are used for subsidy calculations, are projected to increase by 4% on average, while the lowest-cost bronze premiums are expected to rise by 5%. The steepest increases can be seen in Vermont, Alaska, and North Dakota, where unsubsidized monthly costs have surged by 10% or more. Conversely, premiums for low-cost plans are declining in 9 states, with significant reductions in Louisiana. (You can check state-specific data here.) A Peterson-KFF Health System Tracker analysis indicates that increasing hospital expenses and the greater use of GLP-1 medications are key drivers of higher premiums. On a national scale, a benchmark silver premium for a 40-year-old is estimated to be $497 monthly without subsidy assistance. However, the bulk of Marketplace shoppers (92%) qualify for subsidies, and with the enhanced subsidy options, many can secure plans with premiums under $10 per month. Since these subsidies cap monthly payments based on a percentage of an enrollee’s income, the vast majority will not face increased premium costs.
- This may be the final year of enhanced subsidies. The enhanced subsidies established under the Inflation Reduction Act (IRA) are set to expire at the conclusion of 2025. Initially introduced in the American Rescue Plan, these subsidies enhanced premium support for existing enrollees and broadened eligibility for individuals earning above 400% of the poverty line. While these subsidies, which have significantly contributed to high enrollment numbers, will be available throughout 2025, they require Congressional action for any extension into 2026 and beyond. Without the enhanced subsidies, original ACA subsidies will persist, but net premium payments are anticipated to double or more in multiple states come 2026.
- Marketplace shoppers will experience increased insurer options. On average, there will be 9.6 insurers participating in the ACA Marketplaces across states, the highest number recorded in any year to date (state data available here). In 2025, 97% of Healthcare.gov enrollees will have access to three or more ACA insurers, up from 78% in 2021. Several insurers, such as UnitedHealth Group, are venturing into new states in 2025, expanding into 4 new states and 119 additional counties across 13 of the 26 states where they currently participate. Centene (Ambetter) is also expanding its reach into 60 new counties across 10 states. With continual record-high sign-ups and strong financial performance from participating insurers, the ACA Marketplaces are becoming an increasingly appealing market compared to the low participation seen in 2018 (lowest point).
- Open enrollment runs from November 1, 2024, to January 15, 2025, in most states. In line with new federal regulations promoting standardized open enrollment periods, the 2025 season will commence on November 1, 2024, throughout most states, with the exception of Idaho, which began its period on October 15. Open enrollment will conclude on January 15, 2025, in most states, apart from Idaho (December 16, 2024), Massachusetts (January 23), California, New Jersey, New York, Rhode Island, and DC (all January 31).
- More states are shifting to State-Based Marketplaces. Georgia is set to transition to a State-Based Marketplace for the 2025 plan year, raising the total state-based marketplaces to 20. Illinois is scheduled to move to a state-based marketplace for the 2026 plan year and will cease using the federal platform in November 2025. Until then, residents of Illinois should continue utilizing Healthcare.gov.
- The federal government is implementing new anti-fraud measures. The federal government has received numerous reports from consumers who have fallen victim to fraud, where insurance brokers signed them up or altered their plans without consent. To combat this issue, the federal government has undertaken enforcement actions against fraudulent brokers (including suspending certain brokers) and has applied Healthcare.gov standards to web brokers and direct enrollment entities in State-Based Marketplaces.
- Modifications to short-term insurance plans are now in effect. The Biden Administration is reversing the Trump Administration’s expansion of short-term health insurance plans that do not comply with ACA standards and can discriminate against individuals with pre-existing conditions. The new regulations restrict short-term plans to a maximum of 4 months in total, and require that all online and written marketing materials have a consumer notice declaring that the coverage “is NOT comprehensive health coverage.” Although these short-term plans are not available on the ACA Marketplaces, many customers have reported feeling misled into thinking they were purchasing comprehensive insurance. A similar notice must also be included for fixed indemnity policies sold off Marketplace. These policies provide fixed payments in the event of illness or hospitalization, but, like short-term plans, they do not meet most ACA consumer protection standards. Written and online content must indicate that this fixed indemnity coverage “is NOT health insurance.” A recent lawsuit aims to challenge the new notice requirements for fixed indemnity plans, but for the time being, compliance is mandatory.
- Special enrollment opportunities are undergoing changes. HealthCare.gov enrollees with incomes at or below 150% of the federal poverty line will continue to enjoy year-round special enrollment options, though this remains voluntary for state-based marketplaces. However, the “Medicaid Unwinding” special enrollment window will close on November 30, 2024. Additionally, starting in 2025, all consumers who select an ACA Marketplace plan during a special enrollment period (available in both federal and state-based marketplaces) will have their coverage effective from the first day of the month following their selection. Previously, in some state-based marketplaces, coverage initiation for plans selected after the month’s 15th day was delayed until the first day of the second month.
- DACA recipients will be eligible for subsidized Marketplace coverage in 2025. A newly finalized rule by the Biden-Harris administration broadens eligibility for DACA recipients by redefining who is considered “lawfully present.” Starting November 1, 2024, DACA recipients will be able to enroll for coverage through either the Marketplace or the Basic Health Program. They will qualify for premium tax credits and cost-sharing reductions, even if their income is under 100% of FPL. A special enrollment period lasting 60 days will commence on November 1, 2024, allowing newly eligible DACA individuals to enroll. If they enroll in November 2024, their new Marketplace coverage could take effect as early as December 1, 2024. Despite ongoing litigation, DACA recipients remain eligible to enroll.
- Network adequacy regulations must be met. Beginning in 2025, federal Marketplace plans will be obligated to comply with maximum appointment wait-time standards (e.g., no longer than a 10-business day wait for a behavioral health appointment, a maximum of 15 business days for routine primary care appointments, and 30 business days for non-urgent specialty care). Plans are expected to undergo a “secret shopper” survey from 2025 onwards to determine if in-network providers fulfill these appointment wait times for new patients seeking primary and behavioral health care.