The open enrollment period for 2025 ACA (Affordable Care Act)-compliant health insurance is approaching. Let’s explore the significant changes that consumers should note this fall.

For the first time, DACA recipients are anticipated to be eligible to access the Marketplace and qualify for income-driven subsidies, under the same criteria as other applicants. This shift is expected to bring an additional 100,000 enrollees into coverage for 2025.

Nevertheless, attorneys general from 19 states have initiated a lawsuit in a federal district court, aiming to delay and overturn the DACA eligibility rule. Oral arguments are slated for mid-October, and there is a chance that a ruling will be issued just before the commencement of open enrollment. ^{Thus, uncertainty remains regarding DACA recipients’ ability to enroll in Marketplace coverage for 2025.}

This fall, Georgia will operate its own Marketplace platform. Beginning November 1, residents will use Georgia Access – or an approved enhanced direct enrollment entity ^{– for enrolling in or renewing their 2025 coverage. Since 2014, Georgia residents have relied on HealthCare.gov for enrollment, but this option will no longer be available for 2025 and future years.}

Alongside the ACA’s federal premium subsidies and cost-sharing reductions, various states provide additional state-funded subsidies that further reduce premiums, out-of-pocket costs, or both.

For 2025, some alterations to these subsidies include:

• California: A program that launched in 2024 eliminated deductibles and other out-of-pocket costs for applicants with household incomes up to 250% of the federal poverty level (FPL). ^{For 2025, this program is expanding. All Covered California applicants will qualify for plans with zero deductibles and reduced out-of-pocket costs.}
• New Mexico: State out-of-pocket assistance (SOPA) benefits will be expanded, allowing plans with a 90% actuarial value (akin to a Platinum plan) to be available for enrollees with household incomes up to 400% of FPL. ^{In 2024, the income threshold for these 90% actuarial value plans was capped at 300% of the federal poverty level.}
• Colorado: Previously available to enrollees with household incomes up to 250% of FPL, Colorado’s state-funded cost-sharing reductions will see the eligibility limit lowered to 200% of FPL in 2025. Consequently, fewer individuals will qualify; those with incomes between 200% and 250% FPL will be entitled to only the federal cost-sharing reduction, not the state-funded assistance.
• New York: Currently, state-funded Marketplace subsidies are unavailable, but New York has obtained federal authorization to introduce state-funded subsidies starting in 2025. ^{According to the approved waiver amendment, applicants with incomes up to 400% of FPL will qualify for new cost-sharing reductions, plus additional assistance for diabetes care and pregnancy/postpartum support.}

Some enrollees in Oregon may shift to the Basic Health Program

Oregon launched a Basic Health Program – Oregon Health Plan Bridge – in July 2024. Adults with incomes exceeding 138% but not surpassing 200% of FPL are eligible to enroll.

Check our overview of Basic Health Programs.

Marketplace enrollees within this income bracket had the option to transition to the Oregon Health Plan Bridge starting in July 2024, although participation was not mandatory.

When these enrollees update their application (including contact information, projected income, address, family size, or a plan switch during open enrollment), their eligibility for the Oregon Health Plan Bridge will be assessed at that time. Should they qualify for the bridge, they will forfeit eligibility for Marketplace subsidies.

Consequently, individuals who update their Oregon Marketplace account during open enrollment, indicating a projected income eligible for the Oregon Health Plan Bridge, will generally find this coverage to be the best choice for 2025, as they would otherwise incur full costs to maintain their private Marketplace plan.

If an enrollee allows their plan to auto-renew without any updates to the application, they might keep their Marketplace plan up to 2026 (instead of transitioning to the Oregon Health Plan Bridge); however, the state emphasizes that any changes, such as income fluctuations, necessitate updating the application.

Some rates have already been finalized in certain states, while others remain under review. Details for carriers in your state can be accessed by selecting your state on this map.

It’s crucial to note that average rate changes are determined based on full-price (unsubsidized) premiums, and most enrollees do not pay the full amount. As of early 2024, approximately 93% of Marketplace enrollees nationwide were benefiting from premium subsidies that alleviated some or all of their coverage costs.

For subsidy recipients, the net (after-subsidy) premium for 2025 will not only be influenced by changes to their own plan’s premium, but also by fluctuations in the benchmark (second-lowest-cost Silver) plan premium, as the benchmark plan’s cost is pivotal for determining premium subsidy amounts. Review notifications from your insurer and the Marketplace to comprehend how your net premium will shift upon renewing your current coverage.

At least 11 states will experience carrier additions and exits

Each year, transitions occur regarding which insurers participate in Marketplace coverage across several states. While in many areas the list of participating insurers remains unchanged for 2025 compared to 2024, some states will witness new insurers entering the Marketplace, whereas others will see insurers bowing out or ceasing operations in the individual market altogether.

For specifics on 2025 insurer participation and premium adjustments, we maintain individual pages for each state’s Marketplace; here’s a brief overview of carrier movements for 2025:

New Entries:

• UnitedHealthcare – entering Indiana
• HAP CareSource – entering Michigan
• WellSense – entering New Hampshire
• WellPoint – entering Texas, Florida, and Maryland
• Simply Healthcare Plans, Inc. – entering Florida

Exits:

• Celtic – exiting Indiana Marketplace (will continue to offer plans outside the Marketplace)
• Ascension (US Health & Life) – leaving Indiana, Kansas, Tennessee, and Texas
• Cigna – exiting Pennsylvania, ^{South Carolina, and Utah}
• Ambetter/Western Sky – leaving New Mexico
• PacificSource – exiting Washington
• Aetna Life – terminating in Virginia (but Aetna Health will keep offering plans)

If your current insurer is exiting your market at the close of 2024, you must choose a new plan for 2025. You’ll have until December 31 to select a new plan with a January 1 effective date. ^{Depending on your location, the Marketplace may likely automatically assign a replacement plan if you do not choose your own. However, being proactive in choosing your coverage is advisable.}

Changes in insurer participation in the Marketplace will not only influence available plan options but also potentially affect the benchmark plan premium – particularly if new or exiting insurers hold that designation. Variations in the benchmark plan premium will subsequently impact premium subsidy amounts for all in the area who are eligible for subsidies, as subsidy amounts are computed based on the benchmark plan’s cost.

As of September 1, 2024, consumers are now prohibited from purchasing short-term health insurance that lasts longer than four months, including renewals, and non-renewable plans are limited to a maximum duration of three months.

Between late 2018 and August 2024, federal regulations allowed the sale of short-term health policies with durations up to three years. For individuals relying on these longer-term short-term health plans, understanding available options during the 2025 open enrollment period is vital, along with the potential consequences of neglecting to select a new plan during this timeframe.

If your existing short-term policy is set to expire sometime in 2025, you will not be able to obtain another longer-duration short-term policy thereafter. All available options will be capped at a maximum of four months, which could leave you uninsured at some point in 2025. Furthermore, the termination of a short-term policy does not constitute a qualifying life event to trigger a special enrollment period for an individual/family health plan enrollment.

Therefore, if you are currently on a short-term policy that is ending in 2025, consider your Marketplace options during the forthcoming open enrollment period. Enrolling in a Marketplace plan will ensure coverage throughout 2025 and possibly qualify you for federal or state financial assistance with premiums.

Recently, CMS (the Centers for Medicare & Medicaid Services) has taken measures to prevent unauthorized enrollments and plan changes that occurred in states utilizing the federally run Marketplace (HealthCare.gov).

Since July, CMS has put new regulations into effect that prohibit brokers from adding themselves to a person’s HealthCare.gov account without the policyholder’s consent. ^{Previously, some brokers exploited this loophole, receiving commissions for those accounts and modifying plans without the enrollee’s awareness.}

If you wish to assign a different broker to your account, you must either participate in a three-way call with the Marketplace call center and your new broker or log into your HealthCare.gov account to input the new broker’s information. ^{(Here’s how to do that.) This process is necessary for anyone transitioning brokers or who decides to seek assistance after navigating the enrollment process independently.}

Call volume at the Marketplace significantly rises once open enrollment begins. If you know you’ll want to add a broker to your existing HealthCare.gov account or switch to a new broker, consider addressing this ahead of the open enrollment period.

If you reside in a state that operates its own Marketplace (meaning you don’t utilize HealthCare.gov), that Marketplace will have its own guidelines for adding a new broker to your account. The process differs between state-run Marketplaces, but your broker or the Marketplace can clarify the steps needed to accomplish this transfer.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has authored numerous opinions and educational articles about the Affordable Care Act for healthinsurance.org.