Significant ACA Changes:
What Agents Need to Know from the “Big, Beautiful Bill”
Pandora continues to analyze the potential impacts of the “Big, Beautiful Bill” and what it means for you and your ACA clients. The U.S. House of Representatives approved the bill in the second step of its three-step process to become law.
Our analysis focuses on the bill’s changes to the ACA market and their impacts on insurance agents. Here are the initial key updates.
Open Enrollment Period
The bill ends the ACA Open Enrollment Period a month earlier. It proposes ending Open Enrollment on December 15, 2025. Open Enrollment still begins November 1, 2025.
Opportunity For Agents
- In this scenario, ACA prospects will have greater urgency to make choices more quickly.
- With more client urgency, agents need sharper focus, better organization, and proactive communication to achieve higher conversion rates.
- On December 16, 2025, ACA agents should contact their clients with coverage gaps and offer supplemental products to address these gaps (vision, dental), high-cost shares (hospital indemnity), and any other issues your clients need to address.
Special Enrollment Periods (SEPs) (effective January 1, 2026)
- The bill will eliminate the year-round Low-Income Special Election Period (SEP) enrollment opportunity for people with incomes up to 150% of poverty.
- It also limits all ACA Marketplaces to providing SEPs based on individuals’ incomes relative to the poverty line.
- All enrollees must prove eligibility to enroll in ACA plans before enrolling if the bill becomes law.
Opportunity For Agents
- Higher quality clients and better retention of ACA clients with regular, proactive communication.
- Develop a strong supplement product portfolio to assist ACA clients with higher cost shares and premiums.
- Medicare and ICHRA are markets to add to your portfolio to broaden your product reach and client base.
SEPs and Tax Credit Eligibility
(effective in the third calendar month following the date the bill becomes law)
- Low-income SEPs will end.
- Prospects enrolling in an ACA plan with a non-qualified Life Experience (QLE) SEP can’t receive premium tax credits or Cost-Sharing Reductions (CSRs).
Opportunity For Agents
- Agents can see lower churn for current clients.
- Other insurance product opportunities, such as ICHRA, Medicare, and supplemental products, are options to diversify your income profile.
Actuarial Value (effective January 1, 2026)
- Returns to 2022 plan year allowable variation in actuarial value, which ranges between -4 percentage points and +2 percentage points.
- The de minimis variation in actuarial value for silver plans is now +/- 1 percentage point.
Opportunity For Agents
- Agents can see more varieties of plan designs within each metal tier and coverage level, which impact deductibles, copays, and out-of-pocket limits.
- Silver Plans should have less benefit fluctuation and more predictable coverage.
- Agents can more easily tailor coverage that meets a client’s needs.
Premium Adjustment Percentage (PAP) Methodology (effective January 1, 2026)
It reverts to the 2019 PAP methodology, which causes the PAP to grow more slowly and pass more cost-sharing onto ACA consumers over time.
Opportunity For Agents
- Agents need a strong supplement product portfolio, like hospital indemnity, to address high-cost shares and future increasing cost charges ACA clients may face.
ACA Marketplace Coverage Eligibility for Lawfully Present Immigrants (effective January 1, 2027)
- Only lawful permanent residents (LPRs or “green card” holders), Compact of Free Association (COFA) migrants residing in the U.S., or certain immigrants from Cuba are eligible for subsidized ACA Marketplace coverage. Refugees, asylees, and people with Temporary Protected Status are no longer eligible.
- Marketplace eligibility ends for all lawfully present immigrants with incomes under 100% of the FPL on January 1, 2026.
Opportunity For Agents
- Inform any immigrant clients meeting these criteria about their loss of eligibility.
- Confirm with your state’s Medicaid agency if there are any options for these clients to obtain coverage through these programs.
- Fixed indemnity plans could be an option if they permit these clients to enroll.
If you have any questions about how these changes impact your business or how to implement solutions like automation and client outreach strategies, we’re here to help.
Contact us anytime. Our team is ready to provide you with the tools and knowledge you need to stay ahead.
Together, we’ll keep your clients covered and your agency growing. Check out our ACA Contracting now!