Key Changes for ACA Open Enrollment 2027: Premiums, Identity Checks, and Immigration Rules

Shoppers buying Affordable Care Act (ACA) health insurance in 2027 will encounter notable changes during open enrollment, including premium increases, stricter identity verification processes, potential delays when using brokers, and revised subsidy eligibility for certain immigrants.

Consumers should prepare for these adjustments as open enrollment begins November 1 in most states. Idaho, Connecticut, and Massachusetts start earlier, while some states already allow preliminary shopping to compare premium rates.

Overall enrollment is projected to continue declining, largely due to the expiration of enhanced subsidies at the end of 2025. Policy experts note that this led to millions dropping or losing coverage earlier this year.

The Trump administration views the declining enrollment as a success, citing aggressive fraud reduction measures—including the recent cancellation of policies covering 760,000 enrollees suspected of improper registration. Some affected individuals have since regained coverage.

Stricter Identity Verification for High-Risk Applicants

A major change involves increased scrutiny of consumers and agents to prevent fraud and improper enrollments, potentially slowing down the enrollment process.

New guidelines from the Centers for Medicare & Medicaid Services (CMS) apply specifically to those using agents or brokers through the federal marketplace, which serves 29 states. State-based exchanges operate under separate regulations and have generally been more effective at preventing fraudulent sign-ups.

All consumers working with agents on the federal platform must now receive a one-time confirmation code or link to authorize that agent. This is delivered via text, email, or automated call through private enrollment systems. Returning users with outdated contact details must first contact the federal marketplace directly or update information online.Additionally, individuals classified as “high-risk”—such as first-time applicants, those changing states, or consumers working with new or different brokers—must verify their identities independently before proceeding.

Joshua Brooker, head of a Pennsylvania-based insurance agency, suggests CMS may be flagging these groups due to concerns over impersonation or unauthorized switching. He notes that plans with low monthly premiums ($30 or less) are particularly vulnerable targets for fraudulent agents who may cover initial costs while profiting from commissions.

However, Brooker warns that up to one in five consumers might face additional identity checks, which could discourage enrollment altogether.

High-risk applicants must confirm their identity through CMS-approved third parties like Experian, answering personal questions designed to verify authenticity. Those who fail this step may need to contact Experian support or apply manually by creating a healthcare.gov account with uploaded identification documents.

“Some people may struggle not because they’re not legitimate, but due to lack of credit history, recent moves, or name changes,” explains Stacey Pogue, senior fellow at Georgetown University’s Center on Health Insurance Reforms. “While these changes likely curb fraudulent activity, they also introduce new barriers.”

Broker Access Restricted Due to Compliance Concerns

In September, CMS implemented a moratorium preventing new agents from assisting with ACA enrollments for 2027 until at least February. Agents not registered with the federal marketplace in 2026 are excluded during open enrollment.

CMS cited disproportionate compliance issues among newly registered brokers and has removed hundreds of non-compliant agents throughout the year.

Jason Fine, owner of a Florida brokerage firm, supports anti-fraud efforts but expresses concern over implementation challenges. His business typically scales staff during enrollment periods but faces difficulties hiring registered agents due to the moratorium.

“They can afford to keep staff year-round, but smaller agencies often adjust seasonally,” Fine states. “Larger call centers benefit unintentionally from this restriction.”

Agent advocacy groups have filed lawsuits challenging the policy, arguing it unfairly impacts 19,000 professionals seeking to offer ACA plans next year.

“Being new doesn’t make someone fraudulent,” says Ronnell Nolan, president of Health Agents for America. “Agencies invest heavily in training only to find trained workers unable to function.”

Pogue advises consumers to schedule appointments early. “If you rely on an agent, their availability might decrease quickly since fewer brokers will assist with enrollment,” she cautions.

Persistent Affordability Challenges Ahead

Without congressional renewal of enhanced subsidies, most ACA enrollees experienced higher costs in 2025. Higher-income earners lost subsidies entirely amid double-digit premium hikes, significantly increasing out-of-pocket expenses.

Despite reduced financial assistance compared to previous years, most buyers still qualify for income-based subsidies tied to regional benchmark plan premiums—the second-lowest silver-tier option available locally.

“Overall affordability remains relatively stable for many,” notes Louise Norris, health policy analyst at HealthInsurance.org. “It’s not ideal, but manageable if last year’s costs were covered similarly.”

Last year saw an average premium increase of 26%, attributed partly to insurer concerns regarding post-subsidy market exits. General rising healthcare expenditures, inflation, and labor shortages contributed to broader cost escalations.

For 2027, premiums are again anticipated to rise, albeit slightly lower at around 15%. Subsidy cutoffs remain unchanged: $63,840 single income threshold; $86,560 for couples; $109,280 for families of three.

“Affordability continues to be our biggest challenge,” states Anne Petry, co-owner of Jaggi Petry Insurance & Investments in Forsyth, Illinois. “Eventually, there will come a breaking point.”

Experts recommend proactive comparison shopping rather than automatic renewals. Plan benefits and pricing fluctuate annually, even within identical coverage tiers. Several insurers, including Cigna, have reduced or withdrawn entirely from ACA markets.

Norris emphasizes reviewing total package—not just monthly premiums—but also deductibles, copays, and coinsurance obligations. The annual cap on out-of-pocket spending also rises substantially in 2027—from $10,600 individual / $21,200 family to $12,000 / $24,000 respectively—a 13% jump limiting consumer liability before insurer responsibility begins.

Recent legislation affects immigrant eligibility too. The One Big Beautiful Bill Act restricts access for lawful residents including H-1B visa holders, refugees, asylees, individuals with Temporary Protected Status (TPS), and pending green-card applicants unless they meet specific exemptions.

Eligible immigrant categories retaining subsidy access include:

• Green-card holders (permanent legal status)
• Certain Cuban and Haitian immigrants
• Citizens of Micronesian, Marshallese, or Palauan nationality

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