The “Big, Beautiful Bill” has been approved by the U.S. House of Representatives and is now in the second step of its three-step process to become the law. As agents, we care what it says about healthcare in the U.S.
This article starts a series discussing how the bill affects the healthcare markets. These changes are also discussed in depth in an article by KFF.
We begin our analysis with what changes this bill has made in the ACA market and the impacts of these changes on insurance agents.
Open Enrollment Period
The bill ends the ACA Open Enrollment Period a month earlier. It could now end on December 15, 2025. Open Enrollment still begins November 1, 2025.
Opportunity For Agents
- ACA prospects have a greater sense of urgency to make choices more quickly.
- Agents need sharper focus, better organization, and proactive communication to achieve higher conversion rates. This urgency generates more ACA sales activity and revenue.
- On December 16, 2025, ACA agents should reach out to their ACA clients with supplemental products to address coverage 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 eliminates the year-round Low-Income Special Election Period (SEP) enrollment opportunity for people with incomes up to 150% of poverty.
- It 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.
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 is enacted)
- Low-income SEPs 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
- This probably means lower churn of your current clients.
- Other insurance product opportunities, such as ICHRA, Medicare, and supplemental products, are good solutions to explore and add to your portfolio 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 may see more plan diversity in plan designs within each metal tier and coverage level, which affects deductibles, copays, and out-of-pocket limits.
- Tighter AV ranges for Silver Plans should result in less benefit fluctuation and more predictable coverage.
- Agents should 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 supplemental product portfolio that addresses high-cost shares like hospital indemnity to address the future increasing cost charges your 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.
- Effective January 1, 2026, Marketplace eligibility will be eliminated for all lawfully present immigrants with incomes under 100% of the FPL.
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.
ACA Marketplace Coverage Eligibility for Deferred Action for Childhood Arrivals (DACA) Recipients (effective January 1, 2026)
DACA recipients in all states are ineligible to purchase ACA Marketplace coverage as they don’t meet the definition of “lawfully present.”
Opportunity For Agents
- Work with any DACA clients to find any group coverage options and cooperative health coverage they may access in their area.
- Determine if short-term health coverage is an option for your DACA clients.
Cost-sharing Reductions (CSRs) (effective January 1, 2026)
- Fund CSRs through payments from the federal government with explicit congressional appropriation of funds.
- This provision may end “silver-loading,” which reduces premiums for silver plans and subsequently reduces the size of premium tax credits.
Opportunity For Agents
A strong supplementary product portfolio with policies addressing increasing cost shares and premiums is a great idea to help clients facing these rising costs and build your diversified revenue base.
At this time, Agility cannot confirm if these provisions will continue in the bill being approved by the U.S. Senate or in the final bill passed by both the U.S. House and U.S. Senate. We will keep you informed on the latest news about this bill in our blogs.
In an article coming soon, we will cover more ACA changes in verifying personal information, filing and reconciling, recapture of excess premium tax credits, premium underpayments and effectuation of coverage, automatic re-enrollment, and changes in abortion and gender affirming care coverage.
Sebastian Alcantara, our ACA product specialist, is here to help you with any questions about these changes and the opportunities they present to agents. Sebastian can also refer you to our Medicare and Supplement product specialists to answer any questions you have specifically in these product areas.
Contact Agility Producer Support at (866) 590-9771 or email support@enrollinsurance.com for answers to your ICHRA questions. Agility can also add you to our free weekly email list for tips and vital information!
