ACA Open Enrollment 2025: Subsidy Uncertainty Looms
Open enrollment under the Affordable Care Act (ACA) officially opened on Saturday, but it has begun against a backdrop of policy uncertainty: Congress has not yet acted to extend the enhanced subsidies that currently help millions afford their coverage. Healthcare Dive
These expanded premium tax credits—first introduced under the American Rescue Plan Act and later extended by the Inflation Reduction Act—have played a key role in the marketplace’s affordability. If these subsidies aren’t extended beyond the end of the year, many enrollees face steep premium increases in 2026.
In the 30 states using the federal marketplace (Healthcare.gov), rates are projected to increase by an average of 26%. In states operating their own exchanges, average increases are estimated at 17%.
The actual financial burden on consumers could be even higher, especially for low‑ and middle‑income households. The article highlights a family of four in rural Bullock County, Alabama with an annual income around $129,000. Their lowest‑cost Silver plan premium would jump from $872/month in 2025 to nearly $1,897/month in 2026. In that scenario, if they instead switched to a Bronze plan, their deductible could climb from $10,000 to $21,200.
On the coverage‑loss side, the Congressional Budget Office (CBO) estimates about 4 million people could lose health insurance if the subsidies expire. The Urban Institute projects that number could reach as high as 7.3 million.
Industry voices are sounding alarms. The Blue Cross and Blue Shield Association warned the longer Congress delays, the more likely consumers will be “scared away from purchasing coverage.” Insurers are already responding: some are exiting counties or withdrawing from exchanges, citing concerns that younger, healthier enrollees may drop out if costs rise, worsening risk pools.
Although lawmakers technically have until December 31 to act, experts say the clock is already ticking. Delay reduces the time insurers and regulators have to adjust, and early premium previews may discourage enrollee sign‑ups.
As open enrollment continues through mid‑January, consumers must examine their plan options carefully and verify subsidy eligibility while it remains available. Plan type (Bronze vs Silver), deductible levels, and monthly premiums may shift significantly if subsidies are allowed to lapse.
At TLD, we will continue to review policy developments, monitor subsidy discussions, and share updates as new information becomes available. Staying informed is essential for agents, brokers and the clients they serve in this pivotal enrollment season.