For more than a decade, brokers and agents have adapted to steady changes in the Affordable Care Act (ACA) marketplace. Deadlines shifted, subsidy structures evolved, and new compliance requirements arrived in waves. But January 2026 represents something different — not just incremental adjustments, but a structural shift in how agents will experience open enrollment.
This post draws from insights shared in Episode 1 of the Insuring Growth Podcast: “Regulatory Changes and Their Impact on Agents”, featuring e123’s Brendan McLoughlin, President at e123, and Dr. Makayla Lavender, Assistant Professor of Economics at UNLV. In that discussion, they unpacked the policy changes reshaping the ACA marketplace and what those shifts mean for agents, carriers, and consumers.
You can listen to the full episode below.
These changes — from new CMS rules to the sunset of pandemic-era flexibilities — will redefine what agents do during open enrollment, how they serve clients afterward, and what “success” looks like in this business.
A Shorter Window Is Coming
For plan year 2026, the federal open enrollment window remains open through January 15, giving brokers the same cushion they’ve had in recent years to handle late decisions, lingering questions, and last-minute enrollments.
But starting in 2027, that changes. CMS has finalized a rule that shortens the federal enrollment period, ending it December 15 — a return to pre-pandemic timing.
That one-month difference will matter. What was once a manageable extension into January will soon collide with the holidays and year-end planning. For agents, this compression means new strategies for client outreach. Waiting until the last week of the year will lead to a rush. To avoid that, proactive engagement in October and November will become essential.
Use this year as a practice run — a dress rehearsal — for how open enrollment will look in 2027 and beyond.
“We’re not just looking at a tighter deadline; we’re looking at a total reset in how brokers plan their year. December 15 becomes the finish line, not the halfway point.”
— Brendan McLoughlin, President, e123, on the Insuring Growth Podcast
The End of “Set It and Forget It”
For years, millions of consumers have relied on auto-enrollment into $0 premium silver plans. Subsidies meant many households didn’t need to take action to renew coverage. That convenience is beginning to shift.
Starting in plan year 2026, CMS will apply new income‐verification and auto‐reenrollment rules. Most consumers can still be passively reenrolled, but there’s a key change: individuals who don’t update their information may be automatically placed into a similar plan with at least a $5 monthly premium, even if their previous plan was free.
That small charge is meant to prompt engagement, but for many it will cause confusion or frustration. The policy sunsets after 2026, meaning the effect may be temporary.
For brokers, the takeaway is clear: expect more client outreach and follow-up.
January may bring calls from households wondering why their “free” plan suddenly has a bill. Agents who prepare early will minimize surprises and preserve trust.
“Imagine being told for years that your plan is free and automatic — and suddenly it isn’t. That’s not a small change for families. Brokers are going to be the ones explaining why.”
— Dr. Makayla Lavender, Assistant Professor of Economics at UNLV
More Work, More Questions
As if tighter deadlines and new verification rules weren’t enough, brokers are also taking on more of the load.
Federal funding for ACA navigators has fluctuated, but the trend is clear: fewer community resources mean more consumer questions land on brokers’ desks. As verification becomes more complex and coverage options shift, brokers increasingly serve as the primary guide for households trying to stay covered.
At the same time, clients will face higher costs. With enhanced subsidies expiring at the end of 2025, many consumers will see premium increases in 2026. Some will downgrade to bronze plans, others will explore off‐exchange coverage, and some may choose to go uninsured. Each path requires more guidance from brokers.
“When subsidies shrink, decision-making gets harder. Do I downgrade? Do I leave the exchange? Do I go uninsured? Every one of those paths puts more pressure back on the broker.”
— Brendan McLoughlin, President, e123
The Broker’s New Reality
So, what does a broker’s life look like after this enrollment period?
- Busier Decembers: December becomes the true finish line for enrollments.
- Chaotic Januaries: January will be spent resolving billing surprises and explaining changes.
- More Complaints: Consumers accustomed to $0 premium plans may be frustrated by new out-of-pocket costs.
- Heavier Reliance: With fewer navigators available, brokers remain the primary advisors for many households.
In short, open enrollment will demand both speed and stamina. It’s not just about enrolling clients — it’s about preparing them, educating them, and staying engaged after the enrollment period closes.
Strategies to Prepare Now
- Front-load client outreach. Start conversations in October, with reminders in November.
- Educate clients. Use plain language to explain subsidy changes, re-verification rules, and the shorter enrollment window.
- Use technology to scale communication. Automated reminders, email campaigns, and self-service tools reduce one-to-one workload.
- Plan for January support needs. Expect a surge in questions about billing, premiums, and verification.
- Diversify product options. Be ready with off-exchange alternatives for clients evaluating new choices.
Why This Matters for the Industry
The ACA marketplace is at its highest enrollment levels ever, fueled by temporary subsidies and pandemic-era flexibility. Those conditions are ending. The next two years will test whether the marketplace can maintain its size and stability as affordability tightens and processes become more complex.
Agents are at the center of that test. They aren’t just distribution partners; they’re the system’s shock absorbers — translating policy into real choices for households. As 2026 approaches, their role becomes more demanding and more indispensable.
