8 Things to Watch for the 2026 ACA Open Enrollment Period
The 2026 Affordable Care Act (ACA) Open Enrollment period is shaping up to be a complex one, with several factors poised to impact coverage and access. Here are eight key developments to monitor as the enrollment period approaches:
1. Premium Increases & Affordability: While premium tax credits remain available to many, continued premium increases are expected. the extent of these increases will vary by state and plan, and consumers should carefully compare options to find affordable coverage.
2.State-Specific Variations: The ACA landscape continues to evolve at the state level. Several states are pursuing innovative approaches to expand coverage and lower costs,while others are implementing policies that could restrict access. Consumers should be aware of changes specific to their state.
3. Broker Conduct & Fraud Prevention: Concerns persist regarding perhaps fraudulent activity by some brokers. Reports indicate instances were brokers have fraudulently enrolled consumers or switched their marketplace coverage to obtain commission payments from insurance companies. Consumers should be cautious and verify any changes made to their coverage by a broker.
4. DACA Recipient Coverage Loss: A important change impacting coverage eligibility is the loss of access for Deferred Action for Childhood Arrivals (DACA) recipients. A 2024 Biden administration regulation initially allowed DACA recipients to enroll in Marketplace or Basic Health Program (BHP) coverage with premium tax credits and cost-sharing reductions. However, due to a Trump Administration program integrity rule, DACA recipients are no longer eligible as of August 25, 2025. Enrollment for DACA recipients will cease after that date, and most currently enrolled individuals will lose coverage effective September 30, 2025.
5. Program Integrity Rule - Court Stay: Several planned regulatory changes to ACA Marketplace coverage, stemming from a Trump Administration program integrity rule, have been temporarily blocked by a federal court in Maryland. These changes, intended to reduce fraudulent enrollment, were scheduled for the 2026 plan year.
6. City of Columbus v. Kennedy Case: The legal challenge City of Columbus et. al v. kennedy questions the Trump Administration’s authority to implement the program integrity rule. Plaintiffs allege the Administration exceeded its authority under the ACA or failed to justify the new eligibility and enrollment restrictions. A preliminary injunction granted in August 2024 halted implementation of several provisions.
7. Stayed Provisions of the program Integrity Rule: The court’s injunction currently blocks several key provisions, including additional paperwork requirements for consumers verifying income for premium tax credits. It also temporarily prevents a requirement for returning Marketplace enrollees in zero-premium plans to pay a new $5 monthly premium until they actively reenroll. A detailed list of stayed provisions is available from the Centers for Medicare & Medicaid Services (CMS).
8. ongoing Litigation & uncertainty: The City of Columbus case, along with a related case, State of California et al v. Kennedy et al, is expected to take several months to resolve. This ongoing litigation creates uncertainty about whether the stayed provisions will ultimately take effect, potentially impacting the 2026 Open Enrollment period and beyond.
