The information below details the timeframe for anticipated impacts on health insurance marketplaces and their consumers if Congress does not act to extend the enhanced premium tax credit structure set to expire December 21, 2025. Individual states operate on unique timelines; the dates below reflect the earliest month in which a state acts.
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Fall 2024
- Insurers make decisions about whether to participate in Marketplaces in 2026, factoring in uncertainty of enhanced advanced premium tax credits (APTCs) expiring and the potential loss of young and healthy enrollees.
- As soon as September 2024, State-Based Marketplaces (SBMs) will start updating their health plan designs for the 2026 plan year. For example, a state with a standard benefit design, including cost sharing, will work with stakeholders in Fall 2024 for 2026 plans.
- SBMs will make decisions assuming young and healthy people will drop coverage and premiums will increase if Congress does not extend enhanced APTCs in 2024.
Spring 2025
- Proposed rates and health plan filings for 2026 are due to state insurance regulators, with one SBM as early as January 2025.
- Proposed rate increases are made public in every state.
- Insurance carriers dropping out of marketplaces or reducing coverage areas become public.
- High proposed rate increases should be expected unless Congress takes action in 2024. Rates rely on the past, current, and projected insured population. Without certainty about enhanced APTCs, 3.8 million individuals are expected to forego insurancei, many of whom will be healthy and young enrollees. This will spike premiums above already increasing health care costs.
Summer 2025
- SBMs prepare for plan year 2026 open enrollment, including updating APTC calculations in IT systems, renewal notice development, and communication efforts. SBMS must assume that the enhanced APTCs will expire without early Congressional action.
- Systems and consumer-facing communications will be designed and tested assuming increased prices for the plan year 2026.
- Starting in August 2025, SBMs start running eligibility for enrolled customers.
- States approve rates and health plan filings for plan year 2026 with a few finalizing in early Fall 2025.
- Final rate increases are made public in every state and will be higher without early Congressional action.
- 2026 health plans (including rates and summary of benefits and coverage) are loaded into SBMs’ online systems and tested for accuracy by SBMs and/or insurers with one state loading as early as May 2025.
Fall 2025
- 21 million enrollees across all marketplaces will receive a renewal notice with their monthly 2026 premium, including APTC amounts if applicable. Some notices go out as early as July and August 2025; all initial notices go out no later than October 2025.
- As early as September 2025, window shopping is open in marketplaces showing 2026 plan prices and products.
- SBMs transmit renewal enrollment files to insurers to prepare for timely renewal. Insurers send renewal notices to enrolled consumers in Fall 2025 including 2026 premiums and reinforce consumer sticker shock.
- Expect sticker shock from both higher premiums and lower APTCs or no APTCs.
- Expect millions of consumers to drop coverage for 2026.
i Congressional Budget Office, “Budgetary Outcomes Under Alternative Assumptions About Spending and Revenues”, May 2024, https://www.cbo.gov/system/files/2024-05/60114-Budgetary-Outcomes.pdf
