2027 Marketplace Plans
The rules for the ACA Marketplace may be changing. Thanks to a three-part series in Health Affairs (links below), Katie Keith and Matther Fiedler have detailed the major changes to the Marketplace proposed for 2027. Here’s what you need to know about how these changes impact the disability community:
- Bronze plans would be subject to higher cost-sharing for enrollees. This would lead to a higher burden of out-of-pocket costs for people selecting those plans.
- Catastrophic plans would be designed differently, with variable limit, multi-year options. This is meant to encourage people with expensive chronic conditions to stay enrolled throughout the duration of the plan. These plans could vary depending on the disease or condition of the person receiving them. In 2027, the catastrophic plans would have a higher out-of-pocket cost, and would provide less coverage to enrollees. Additionally, these types of plans could pull more people out of the risk pool for ACA compliant plans which could cause premiums to rise for those enrolled in ACA compliant plans.
- The proposed rule would also eliminate the low-income Special Enrollment Period (SEP). This SEP provided a path coverage for anyone under 150% of the Federal Poverty Level and essentially created a continuous open enrollment for these individuals.
- Qualified Health Plans (QSPs) would no longer be required to help reduce health disparities. This means, they would no longer be incentivized to reimburse for activities that lead to long-term improvements in health and wellness. This could reduce access to essential care for people with disabilities.
- State-based exchanges would be allowed to open an “enhanced direct enrollment” option. This would mean that even with eligibility determinations being done by the state, enrollment would happen on third-party websites run by private companies. This raises concerns around meeting accessibility requirements, though the regulations would still apply.
According to Health Affairs, these rule changes are expected to in 2027, while costing over $1.3 billion annually to administer. Premiums are expected to rise by over 3%, causing even greater cost burden for the already-squeezed enrollee. Without the extension of enhanced premium tax credits, people with disabilities are among the many people across the U.S. struggling to afford their health care. The Commonwealth Fund details the issue with these rule changes in broader terms:
The proposed rule continues to restrict Americans’ access to health care. Fewer people will have health insurance. Many who have insurance have plans with high deductibles and copayments. This reality runs counter to an ever-expanding body of evidence that shows that being uninsured or underinsured significantly reduces people’s access to health care, substantially increases the risk of medical debt, and leads to poorer health and shorter lives, particularly among households with middle or low incomes. The administration’s actions demonstrate a disconnect from the reality of our extremely costly health care system.
The public comment period for the proposed rules is open through March 13, 2026. Comments can be submitted through the Federal Register page. Check out this resource from Families USA for additional issues with the proposed rules.
Summary of the referenced Health Affairs articles, provided by Katie Keith:
- The first article summarized proposed changes to catastrophic plans; new policies to implement the OBBBA; new cost-sharing reduction (CSR) reporting requirements; and various verification requirements that were previously set aside in court.
- The second article summarized the proposed rule’s changes to essential health benefits requirements, standardized plans, network adequacy, essential community providers, and risk adjustment.
- The third article addresses the proposed rule’s changes to exchange requirements—including a new option for state-based exchanges (SBEs) to rely on enhanced direct enrollment (EDE)—and new oversight standards for insurers as well as agents and brokers.
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