ACA Open Enrollment Begins in the US: Higher Premiums, Tighter Identity Checks and New Limits on Brokers

Open enrollment for Affordable Care Act (ACA) health insurance for 2027 coverage has begun in the United States. Consumers will see changes both big and small, including premium increases, possible additional identity checks, potential delays in working with a broker, and new limits on which immigrants can get subsidies.

Open enrollment started on November 1 in most states and runs through January 15. Idaho, Connecticut and Massachusetts started earlier, and some states have been allowing 'window shopping' to check premium rates. The ACA marketplaces can be found at HealthCare.gov.

A continued decline in overall enrollment is expected, mainly because of the expiration of enhanced subsidies at the end of 2025. Policy experts say the end of those subsidies led millions to drop or lose coverage through the first few months of this year.

But the Trump administration sees victory in the falling enrollment, crediting its various efforts to reduce fraud, including the August cancellation of policies covering 760,000 enrollees suspected to be improperly signed up. A small number of those enrollees have regained coverage.

One of the biggest changes for people shopping for their 2027 coverage will be increased scrutiny of both consumers and agents. The requirements are aimed at thwarting fraud or improper enrollments. For consumers, it could slow the enrollment process.

The new rules, outlined by the Centers for Medicare & Medicaid Services (CMS), affect only consumers using agents or brokers to help them enroll through the federal marketplace, which serves 29 states. They do not apply to state-based exchanges, which have their own rules and have in most cases been more successful at preventing fraudulent sign-ups.

For starters, all consumers using an agent in the federal marketplace will need to get a one-time confirmation code or link to authorize a specific agent to enroll them or make changes on their behalf. It will be sent to consumers by text message, email, or an automated phone call from one of the private enrollment platforms used by their agent. Returning consumers who have incorrect or outdated contact information will first need to call the federal marketplace themselves or submit an application online to update it.

Additionally, consumers and policyholders deemed 'high-risk' must verify their own identity before authorizing an agent. CMS defines as 'high-risk' first-time applicants or those with existing coverage whose applications involve a change of state, as well as consumers working with a new or different agent or with a monthly premium payment of $30 or less.

Joshua Brooker, who oversees an insurance agency in Pennsylvania, said CMS appears to have selected people in those groups for greater scrutiny because "someone who is moving to a new state or switching brokers — that could be a broker trying to impersonate a consumer."

The $30-a-month cutoff may be tied to concerns that plans with no or low monthly premiums are easier for bad agents to target for unauthorized enrollments because the policyholder may never get a bill. Brooker said some rogue agents even pay the low monthly amount themselves and still make a profit from the commission.

The broad nature of the new rules, though, has Brooker concerned "that up to 1 in 5 consumers is going to have to do extra identity proofing" and may just give up and not get insured.

Consumers designated high-risk must prove their identity through a CMS-approved third party such as credit company Experian, which generally asks questions only the consumer should be able to answer. People who fail this test may be asked to call Experian's help desk or submit their applications themselves by creating a healthcare.gov account, which requires them to upload identification such as a driver's license, a passport, immigration papers, or another form of ID.

Stacey Pogue, a senior research fellow at the Center on Health Insurance Reforms at Georgetown University, said: "Some people may have trouble not because they're not real, but because they don't have a credit file, or have moved, or have changed names." She said the changes might "be an appropriate response by CMS that targets fraudulent enrollments but might also create extra hurdles."

CMS in September issued a rule that places a moratorium on brokers new to offering ACA coverage. Agents not registered with the federal marketplace in 2026 will not be allowed to assist with enrollments for 2027 until February at the earliest, past the end of open enrollment season.

CMS said it took this step because a disproportionate number of "significant compliance concerns" in 2026 came from newly registered agents or brokers. Additionally, the agency has kicked out "hundreds of non-compliant agents and brokers" this year.

Jason Fine, who runs a brokerage in Florida, said he agrees with the concept behind these changes. He has reported multiple times to CMS, for instance, that rogue agents have switched his clients' coverage without authorization, wanting the agency to take action against them. But he said the updated rules also raise concerns. He said: "Everything they are doing in the long term makes sense. However, in the short term, I don't know if they care about the chaos it will cause."

That is because the moratorium will make it much harder for small brokers to help clients this year. His agency and others often pare their staffing after open enrollment but hire again toward the end of the year. He was planning to add up to 10 agents to his core staff of about five but has been told by recruiters that he's unlikely to be able to find anyone who was registered for 2026 and is still available.

He suggested that the move unintentionally benefits larger call centers, some of which were doing much of the marketing that regulators feared led to unauthorized switching. Call centers often maintain larger staffs. Fine said: "They can afford to keep a staff of 25 or 40 people all year long."

Groups representing agents are very unhappy with the directive. The National Association of Benefits and Insurance Professionals filed a lawsuit on October 15 against the Trump administration over the moratorium, saying it unfairly targets 19,000 agents who may want to sell ACA plans for next year.

Ronnell Nolan, president of Health Agents for America, which on October 21 filed suit seeking a temporary restraining order on the moratorium, said: "Just because you're a new agent doesn't mean you are fraudulent. All these agencies who have trained new agents and paid thousands of dollars now have people who won't be able to work."

It all leads to an important piece of advice from Georgetown's Pogue: consumers should not delay making appointments. She said: "If you rely on an agent or broker, and a lot of people do, their slots might fill up faster because there will be fewer of them to help with enrollment. I would reach out early."

This year, after Congress did not renew the expiring enhanced subsidies, most people getting ACA coverage saw what they had to pay increase. Higher earners lost subsidies entirely. Add in double-digit premium increases, and most people had to pay substantially more for their coverage.

Still, most people who buy ACA coverage for next year will receive a subsidy. It will just be less generous than it was before the enhancements expired at the end of 2025. The subsidies are pegged to the premium costs of benchmark plans, the name given to the second-lowest-price silver-tier plan in an area.

Louise Norris, a health policy analyst for HealthInsurance.org, said: "For most folks, overall affordability will stay about the same. That's not to say it's great, but if you were able to manage the premiums this year, it should be similar to that."

Last year's average premium increase of 26 percent was the largest in years. It was driven in part by insurers' fear that the expiration of subsidies would cause healthier people to drop out of the marketplace. Other drivers often cited for such increases include a rise in overall medical care costs and general inflation, and labor shortages.

For the upcoming year, those dynamics remain a concern, with premiums slated for double-digit increases, although, at 15 percent, slightly lower than last year.

Subsidies are income-based and cut off for households earning more than four times the federal poverty rate. During this open enrollment season, that amount is $63,840 for a single person, $86,560 for a couple, and $109,280 for a family of three, for example.