Big changes are coming to ACA Marketplace and Medicaid coverage, and they will directly affect eligibility, enrollment timelines, and how millions of Americans maintain their health insurance.
At CITIZ3N, we’re laser-focused on helping agencies, carriers, and exchanges keep members engaged and informed. As your partners in creating consumer-centered digital experiences, we’re here to help you navigate these shifts with minimal disruption and maximum transparency.
What’s Driving These Changes?
Two major federal moves have landed this summer:
The One Big Beautiful Bill Act (OBBA) – Congress’s sweeping budget reconciliation bill (H.R.1, 119th Congress) — and
The CMS “Marketplace Integrity and Affordability” Final Rule, finalized on June 25, 2025.
Together, these drive the most significant ACA operational changes since the post-COVID continuous coverage unwinding.
The goals?
- Tighter eligibility verification
- Less automatic re-enrollment
- Shorter enrollment windows
- Reduced federal costs and fraud
But these same measures will also leave more people at risk of losing coverage if they don’t take proactive steps.
Read Softheon’s full breakdown of the new federal rules ➔
Key Changes You Need to Know
A Shorter Open Enrollment Window (Starts Fall 2026 for Plan Year 2027)
- Current: Nov 1 – Jan 15 (federal platform)
- New: Nov 1 – Dec 15.
- Most state-based marketplaces (SBMs) will also be capped at December.
That means 30 fewer days for consumers to shop and enroll, putting added pressure on outreach campaigns, plan comparison tools, and support centers.
End of the Low-Income Special Enrollment Period (August 2025)
- The monthly SEP for people earning ≤150% FPL will be eliminated.
- This was a major “backstop” that kept lower-income families insured throughout the year.
Phasing Out Automatic Re-Enrollment for Subsidized Plans
- For Plan Year 2026, households that would otherwise auto-renew at $0 premiums will need to pay at least $5/month (or actively re-certify).
- By Plan Year 2027, automatic re-enrollment is eliminated for all subsidy-eligible plans.
Without smart nudges and reminders, we could see substantial drops in passive renewals.
Tougher Verification Rules
Starting next month (August 2025):
- No more 60-day grace period on income inconsistencies — it’s 90 days firm.
- More income attestations will require documentation, especially if data shows income <100% FPL or if IRS data is missing.
And for SEPs in Plan Year 2026, at least 75% of new enrollments will require verification documentation.
DACA Eligibility Reversal (August 2025)
- DACA recipients will no longer be eligible for ACA coverage or subsidies.
What About ICHRA, CHOICE, and CSRs?
You may have heard these were part of OBBA — and they were, originally. But in the final Senate-passed version:
- ICHRA codification (CHOICE arrangements) was stripped out.
- Appropriations for CSR payments were also removed.
Both issues are likely to come back in later 2025 “health extender” discussions, which could also tackle enhanced premium subsidies. We’re tracking this closely alongside Softheon’s policy team.
What This Means for Member Experience & Operations
More Proactive Outreach Needed
With shorter enrollment windows and the end of “always on” low-income SEPs, agencies and health plans need to get in front of consumers earlier through SMS, email, and outbound campaigns.
Smarter Digital Journeys
- Expect more consumers to drop off without intuitive dashboards showing eligibility statuses, document uploads, and deadline trackers.
- Integrated digital reminders (via text, push, and secure messages) will be critical to reduce churn.
New Operational Loads
- Eligibility teams will face higher documentation rates.
- Call centers may see spikes from consumers confused about SEP changes, minimum premium requirements, or why they can’t auto-renew.
How CITIZ3N Helps
At CITIZ3N, we specialize in:
- Member engagement platforms that drive proactive renewals and reduce friction.
- Personalized digital journeys that meet people where they are, with tailored nudges.
- Data-driven communication tools that simplify eligibility and document management.
We’re closely aligned with our parent brand Softheon, who provides the enrollment and billing infrastructure for many of these programs nationwide — and who is already deploying system updates to comply with these new rules.
Bottom Line: Prepare Now
This is the biggest operational pivot for ACA Marketplace and Medicaid programs since 2021. Failing to adapt could mean a surge in uninsurance, higher uncompensated care, and compliance risks.
If you’d like to explore how CITIZ3N can help modernize your engagement strategy ahead of these changes, we’re here to partner with you.
Let’s ensure your members stay covered.
Want a more technical dive?
Check out Softheon’s policy update here ➔ for enrollment rule timelines, documentation triggers, and platform readiness checklists.
