Open Enrollment Starts Today. The ACA Marketplace Looks Very Different.

Open enrollment for 2027 health coverage under the Affordable Care Act began Sunday in most states, and consumers shopping the federal marketplace will find a landscape that has shifted in nearly every direction at once. Costs are higher, verification requirements are stricter, and millions of people who held coverage a year ago no longer do.

The most consequential change happened before enrollment opened. Enhanced federal subsidies that had held premiums down since 2021 expired at the end of 2025. Their loss pushed costs up sharply for many buyers and, according to policy experts, prompted a steep decline in enrollment as people dropped coverage or were priced out. The pool that remains tends to skew toward people with greater health needs, which in turn gives insurers reason to raise premiums further.

Last year's average premium increase was 26 percent, the largest in years. For 2027, premiums are projected to rise roughly 15 percent. Subsidies remain available to most buyers, but they are less generous than under the expired enhancements, meaning the same plan costs more out of pocket than it did two years ago. Deductibles and out-of-pocket maximums have also shifted, so equivalent coverage can carry a very different price tag depending on the plan and the state.

A New Layer of Verification

The 29 states that use the federal marketplace, run by the Centers for Medicare and Medicaid Services, are also operating under new enrollment rules designed to combat fraud. In recent years, bad actors exploited the system by switching consumers into plans without their knowledge, sometimes to capture commissions or to game subsidy calculations. CMS has responded with identity verification requirements that apply broadly, not just to suspected fraud cases.

Consumers who use an agent or broker to enroll must now receive a one-time confirmation code or link and use it to authorize the agent to act on their behalf. That step alone adds friction to a process that has historically relied on brokers to guide lower-income and first-time enrollees through a complicated system.

A subset of consumers flagged as higher-risk face an additional step: verifying their identity through a CMS-approved third party. Joshua Brooker, who runs an insurance agency in Pennsylvania, estimates that as many as one in five consumers could be subjected to this extra proofing. The concern is not that the step is unreasonable in principle but that it can block people who pose no fraud risk at all. Stacey Pogue, a senior research fellow at Georgetown University's Center on Health Insurance Reforms, notes that consumers may fail verification simply because they lack a credit file, have recently moved, or have changed their names. None of those circumstances signal fraud, but the verification systems used by third-party services often rely on exactly the kind of stable financial history that lower-income consumers are less likely to have.

Brokers Caught in the Middle

The broker landscape has its own disruption. CMS issued a moratorium barring agents who were not already registered with the federal marketplace in 2026 from assisting with 2027 enrollments until at least February. The agency's stated goal is to keep out bad actors who rotated in under new identities after prior enforcement actions.

Industry groups have pushed back, arguing the moratorium penalizes new agents who completed their training in good faith and have no connection to the fraud schemes that prompted the crackdown. For consumers who relied on a newer broker to navigate enrollment, the moratorium may mean starting over with someone unfamiliar or attempting to enroll without professional help.

The combined effect is a narrowed broker pipeline at a moment when the enrollment process requires more documentation and more steps than it did a year ago. Consumer assistance organizations and navigators, who are federally funded to help people enroll without charging fees, are likely to see increased demand.

What Shoppers Need to Know

For people entering the marketplace this year, price comparison matters more than usual. Because premium structures have shifted and subsidy values have changed, a plan that looked like the best deal in 2026 may not be in 2027. Shoppers should look at the full cost picture: monthly premium, annual deductible, copays, and the out-of-pocket maximum, which is the most any enrollee would pay in a given year before insurance covers everything.

People who use a broker should expect the new authorization step and should be prepared to complete it promptly. Those who receive a notice about additional identity verification should not ignore it. Failing to complete the process will block enrollment, and the window closes in most states on January 15.

Consumers without a broker who need help can find free enrollment assistance through HealthCare.gov's local help finder or through community health centers, many of which staff trained navigators during the enrollment period.

The Durable Question

The changes in place for 2027 carry a genuine tension at their center. The verification requirements and broker restrictions exist because documented fraud caused real harm to real consumers. The question, one that will be answered partly by enrollment numbers and partly by who is turned away, is whether the corrective measures fall on the people who committed the fraud or on the people who simply needed coverage and ran into a system that became harder to use.

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