Hobbling towards Enrollment: My 2027 ACA Open Enrollment Guide (Part 3)

Sat, 10/31/2026 - 8:43pm

In Part 1 of my 2027 ACA Open Enrollment Guide, I covered:

  • The Federal Poverty Level (FPL) household income guidelines for calendar year 2027
  • The Open Enrollment Period (OEP) deadlines for every state, including exceptions/special cases
  • The official ACA Exchange/Marketplaces to use to shop for & enroll in healthcare coverage
  • The 2027 Advance Premium Tax Credit (APTC) household income table for calculating subsidy eligibility
  • Ways to legally keep your Modified Adjusted Gross Income (MAGI) below the 400% FPL subsidy eligibility cut-off threshold, and...
  • A reminder that starting this year, there's no longer any caps on what portion of those subsidies you might have to pay back if your actual MAGI ends up being higher than you anticipated.

In Part 2, I covered...

  • How important it is for those enrolled in off-exchange plans to strongly consider moving to an on-exchange plan even if they suspect they won't be eligible for federal subsidies
  • A breakout of the fifteen states which offer additional financial savings to eligible on-exchange enrollees to help mitigate the loss of federal subsidies (including 2 additional states in 2027)

Today I'm wrapping things up by reminding you that...

9. MILLIONS OF PEOPLE ARE ELIGIBLE FOR "SECRET PLATINUM" PLANS (LABELED AS SILVER)!

As I explain in detail here, if your household earns less than 200% FPL in any state, you're likely better off with a SILVER plan!*

Thanks to the ACA's Cost Sharing Reductions (CSR) system, you'll receive additional financial help which will lower your deductible, co-pays and coinsurance so much it effectively transforms Silver plans into Platinum plans!

Thankfully, unlike premium subsidies, the CSR subsidy formula is not being weakened in 2027, so this is still good advice regardless of the premium tax credit debacle.

10. SOME SUBSIDIZED ENROLLEES MAY BE ABLE TO GET BRONZE OR EVEN GOLD PLANS FOR FREE!

I've written multiple times in the past about "Silver Loading," the ACA health insurance policy pricing strategy in which insurance carriers load the extra cost of their Cost Sharing Reduction financial burden (the portion of deductibles, co-pays & coinsurance which they're required to cover themselves for low-income enrollees who select Silver plans) onto the gross premium of those same Silver plans.

It gets a bit wonky, but the bottom line is that Silver Loading results in the gross price of Silver ACA plans increasing significantly even if the price of Bronze, Gold & Platinum plans only go up modestly. This may sound bad, but stay with me.

From the carriers perspective, how the CSR load is allocated doesn't matter much as long as they aren't left stuck with the bill...but pricing the plans in this fashion has major implications for the enrollees themselves.

This is because the formula for the ACA's advance premium tax credit subsides (APTC) is based on the gross price of Silver plans: If the price of Silver plans increases, so do the subsidies for those eligible..but you can use APTC to enroll in non-Silver plans if you wish.

This in turn means that if Silver plans go up by, say, 30% while Bronze & Gold only go up by 10%, the net premium you pay for a Bronze or Gold plan will be significantly lower.

Even before the enhanced tax credits went into effect five years ago, there were some parts of the country where some enrollees could get Bronze plans for free, while Gold plans (which have lower deductibles/etc than non-CSR Silver plans) could cost the same or even less than Silver, as backwards sounding as this may seem. There are even some people who qualified for $0-premium Gold plans.

It's important to note that Silver Loading is only relevant (or should only be relevant) for enrollees who earn more than 200% of the Federal Poverty Level (FPL), since those who earn less than 200% FPL should usually* stick with Silver plans to take advantage of the more generous high CSR assistance itself.

Again, CSR turns Silver plans into "Secret Platinum" plans by boosting their Actuarial Value (AV) from around ~70% (standard Silver) to either ~94% (for enrollees who earn up to 150% FPL) or 87% (enrollees who earn 150 - 200% FPL). In simple English, high CSR plans have dramatically lower deductibles, co-pays & coinsurance than Bronze, standard Silver or even Gold plans.

For enrollees over 200% FPL**, the enhanced tax credits have dramatically strengthened the impact of Silver Loading, of course, allowing far more people to become eligible for more comprehensive & affordable ACA plans across the board. Those earning 200 - 400% FPL have been able to leverage Silver Loading even more to their advantage, while those earning over 400% FPL--who previously weren't eligible for any financial assistance whatsoever--were able to utilize both the expanded subsidies and Silver Loading to get a better value.

The subsidy formula reverting back to pre-2021 levels (actually even worse than that, but that's another discussion) is still devastating to millions, of course, but it would be far worse for millions of over-200% FPL enrollees if Silver Loading wasn't an option...even if most of them don't realize they're benefiting from it.

However, Silver Loading is actually effectively a subset of another ACA pricing policy called Premium Alignment.

Premium Alignment (PA) gets even wonkier; I'm not going to explain it here again, but the bottom line is that PA maximizes APTC subsidies even further, resulting in even more dramatic improvements in value and affordability for millions of ACA enrollees.

As a bonus, states which implement PA are actually complying with the spirit of the legislative text of the ACA itself more closely than states which aren't doing so. As a further bonus, PA is actually completely non-partisan: States which have implemented it include blue states like New Mexico and Maryland...but also red states like Wyoming and Texas.

In 2026, three more states newly-implemented robust PA policies...and again, these include two blue states (Washington and Illinois) and one deep red one (Arkansas).

In the end, subsidized enrollees earning 200% FPL or more may be eligible to enroll in a Gold plan for less than Silver, or a Bronze plan for free!).

Even with the enhanced tax credits having expired, there are still hundreds of counties where at least one Gold plan is priced lower than the benchmark Silver plan even at full price! In fact, after subsidies, some people still qualify for a ZERO-PREMIUM GOLD plans!

(Granted, the enhanced tax credits expiring means that there's a lot fewer people who qualify these days...)

*This isn’t a universal truth; there are some cases where someone below 200% FPL might be better off with a dirt-cheap Bronze or Gold plan.

**CSR assistance is also available to enrollees who earn 200 - 250% FPL, but it’s far weaker at this level (73% AV) than under 200% FPL, so it’s more of a judgement call as to whether a CSR Silver or a Silver Loaded Gold plan is a better option.

11. THE INDIVIDUAL MANDATE IS STILL AROUND IN FIVE STATES!

The federal ACA individual mandate was reduced to nothing in 2019, so it isn't an issue any longer...but there are actually five states which have their own healthcare coverage requirement/penalty:

The financial penalty for not having coverage (assuming you don't qualify for an exemption, which some people will) will be charged when residents file their 2026 state taxes in spring 2027.

12. SOME CARRIERS ARE EITHER NEWLY ENTERING OR EXITING STATES

Every year sees churn on the ACA markets as new carriers enter or expand their coverage areas to more counties/states...or as currently-participating carriers pull out of them. In addition, existing carriers often add new plans or phase out current ones.

My colleague Louise Norris has compiled what should be a fairly comprehensive list of new entrances and exits for 2027, though it's possible that she and/or I have missed a few:

Newly Entering:

  • California: CalOptima Health
  • Colorado: Colorado Access (in 4 of the 9 rating areas)
  • Georgia: Antidote Health
  • Indiana: AmeriHealth Caritas
  • Minnesota: Aspirus
  • Ohio: AmeriHealth Caritas
  • South Carolina: Oscar Health
  • Texas: Antidote Health
  • West Virginia: Peak Health

Newly Exiting:

  • Arizona: Cigna (pulling out nationally)
  • Arkansas: Ambetter, QualChoice Life & Health (these are both Celtic/Ambetter/Centene subsidiaries; C/A/C will still be offering plans via one remaining carrier)
  • Colorado: Cigna
  • Connecticut: ConnectiCare Insurance Co (they'll still offer plans off-exchange)
  • Delaware: Celtic/Ambetter/Centene
  • Florida: Molina; Sunshine State Health Plan (enrollees will be transitioned to a different Ambetter/Centene plan if they don't pick one)
  • Georgia: Cigna; UnitedHealthcare
  • Idaho: PacificSource
  • Illinois: Cigna; Molina
  • Indiana: Cigna; CareSource
  • Iowa: Medica
  • Kansas: Medica
  • Kentucky: Molina
  • Maine: Mending (formerly Taro Health)
  • Minnesota: UCare (this is due to UCare being acquired by Medica, however)
  • Mississippi: Cigna; Molina
  • Missouri: Cox Health Plans (they'll still offer plans off-exchange)
  • Montana: PacificSource
  • New Hampshire: Celtic/Ambetter/Centene
  • North Carolina: Cigna
  • Ohio: CareSource; Molina
  • Oklahoma: Mending (formerly Taro Health); Medica
  • Oregon: PacificSource; Providence Health Plan
  • South Carolina: Molina
  • Tennessee: Cigna
  • Texas: Cigna; Baylor Scott & White Health Plan
  • Utah: Molina
  • Virginia: Cigna
  • West Virginia: CareSource

Any time a carrier reduces their participation in a given county or state it means that anyone currently enrolled in their policies will either be automatically "mapped" to a similar plan with a different carrier or they have to actively seek out a new policy to enroll in.

If this is all confusing, I'm afraid you'll receive a lot less assistance than in past years in most states because...

13. THE FEDERAL NAVIGATOR PROGRAM BUDGET HAS BEEN GUTTED BY 90%.

As noted by KFF earlier in 2025:

The U.S. Department of Health and Human Service’s announcement of a 90% cut in Navigator funding, while not surprising, is the biggest cut since the program began. The current plan year funding of $100 million will be reduced to $10 million for next year. Congress created the Navigator grant program to provide consumers with “fair and impartial information and services” related to ACA Marketplace coverage.

During the first Trump administration, funding was reduced by 84%, resulting in staff layoffs, reduced outreach, and limitations on the time these assisters can spend with individuals. These funds were restored in 2021 under the Biden administration and last year, the administration announced up to $500 million over five years, providing $100 million for the 2025 plan year– the largest grant amount since the program began. Grants awarded for plan year 2024 (as well as plan year 2025) disproportionately serve patients and consumers in Republican-led states and rural areas (Figure 1).

...The ACA requires Navigators to perform functions much broader than enrolling individuals in ACA coverage. These entities also conduct public education and outreach activities, especially in underserved communities where people’s income can fluctuate during the year due to job loss and other circumstances beyond their control. For this population, Navigators provide information about not only ACA eligibility and enrollment but also Medicaid and employer coverage for low-income populations—as many people with low incomes transition across these coverage types.

The good news is that there are now 22 states operating their own state-based ACA marketplaces (Oregon recently launched their new SBM) which also have their own marketing, outreach and navigation programs independent of the one operated by the HHS Dept. for HealthCare.Gov states. Still, that $90 million funding cut is pretty devastating across the other 29 states.

14. THOUSANDS MORE IMMIGRANTS ARE ABOUT TO BE THROWN UNDER THE BUS BY THE GOP’S BIG UGLY BILL.

or 2026, the Trump Regime screwed over hundreds of thousands of documented non-citizens by declaring them no longer eligible for ACA subsidies, including DACA recipients and recent documented immigrants who aren't eligible for Medicaid because they've lived here for less than 5 years.

For 2027, the list of those no longer eligible to receive subsidies via ACA exchange plans is going to grow even longer. Via the National Immigration Law Center:

Starting November 1, 2026, when open enrollment for the Affordable Care Act coverage begins, many previously eligible immigrants will lose the ability to obtain ACA tax credits and cost-sharing help and may be unable to afford full-price coverage for plan year 2027.

The new law means fewer categories of immigrants can get help buying health insurance through the ACA Marketplaces.

The categories of noncitizens who remain eligible for ACA subsidies are:

All other lawfully present immigrants will lose eligibility for financial support, including:

  • Refugees; asylum applicants and recipients; people who applied for or received withholding of removal/deportation
  • Survivors of violence petitioning for lawful status under the Violence Against Women Act

(yes, that’s right: even victims of domestic abuse and human trafficking are now SOL.)

  • T visa holders, bona fide applicants for T visas, and U visa holders (survivors of crime and trafficking)
  • People paroled into the U.S. for more than one year and certain Afghan and Ukrainian parolees
  • Green-card applicants
  • Applicants for Temporary Protected Status with work authorization and TPS holders
  • People granted Deferred Enforced Departure or deferred action (other than DACA)
  • People who have petitioned for or received Special Immigrant Juvenile classification
  • Individuals granted Continued Presence
  • Certain immigrants with work authorization, including nonimmigrants in “compelling circumstances,” applicants for registry, applicants for adjustment under the LIFE Act, applicants for cancellation of removal/suspension of deportation, individuals under orders of supervision
  • Lawful temporary residents and applicants for legalization
  • Individuals with Family Unity

Technically speaking these populations are still eligible to enroll in exchange plans, but they’d have to pay full price which, of course, the vast majority of them likely would be unable to afford, making that a pretty small silver lining (not to mention that with the Trump ICE Gestapo running around rounding up every immigrant they can find whether they’re here legally or not, I can’t imagine too many on the above list would be inclined to do so even if they can afford it financially).

15. DON'T LET YOURSELF BE PASSIVELY AUTO-RENEWED!

It's always been a good idea to actively shop around the ACA marketplace each Open Enrollment Period to see whether there's a better value for the upcoming year, but it's even more important now.

Between the expired federal tax credits, the less-generous APTC and MOOP thresholds, the changes in carrier participation (both new entries and exits), the changing supplemental financial assistance being provided in a dozen or so states, the seemingly counterintuitive pricing structure caused by "Silver Loading" and a host of other factors, you should absolutely NOT let yourself be "auto-renewed" this year!

My friend & colleague Louise Norris lists some important reasons for this:

  • In most states, you’ll have limited opportunities to pick a new plan after your coverage is auto-renewed. The auto-renewal process happens right after December 15, for people who haven’t manually renewed or selected a new plan. Since open enrollment extends into January in nearly every state (for now), enrollees in most states have until at least January 15 to pick a new plan if they ended up deciding that the auto-renewed option wasn’t the best choice after all.

  • Your subsidy amount will generally change from one year to the next. If your subsidy gets smaller, auto-renewal could result in higher premiums next year (and almost certainly will this year). If the cost of the benchmark plan changes, premium subsidy amounts in that area will also change. The benchmark plan for 2027 may or may not be the same plan that held the benchmark spot in 2026.

  • If you receive a subsidy, auto-renewal could be dicey even if the subsidy amount isn’t declining. If you rely on auto-renewal (as opposed to manually renewing and completing the financial eligibility determination process for the coming year), the exchange can renew your plan without a premium subsidy in certain circumstances. This includes situations in which you didn’t give the exchange permission to access your financial information in subsequent years, or if you failed to reconcile your premium subsidy on the prior year’s tax return.

  • If your plan is being discontinued at the end of 2025, auto-renewal will result in the exchange or your insurer picking a new plan for you. They will try to assign you to the plan that most closely matches the coverage you had in 2025, but selecting your own new plan is a better option.

  • Auto-renewal might result in a missed opportunity for a better value. Even if the plan you have in 2026 represented the best value when you selected it, there may be different plans available for 2027.

  • Provider networks and benefit structures can change from one year to the next, as can premiums. You might still decide that renewing your 2026 plan is the best option for 2027. But it’s definitely better to actively make that decision rather than letting your plan auto-renew without considering the other available options.

And once again, all of this is even more true for 2027 due to the enhanced tax credits having expired at the end of 2025.

IN SHORT: SHOP AROUND, SHOP AROUND, SHOP AROUND!

I’m sure I’ve missed some items, but this should cover the bulk of it. Good luck to us all; we’re gonna need it.

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