ACA open enrollment: what’s new for 2025

Open enrollment for 2025 ACA (Affordable Care Act)-compliant health insurance is just around the corner. Let’s take a look at the various changes that consumers should be aware of this fall.

DACA recipients will be eligible to use the Marketplace

UPDATE: On December 9, 2024, a federal judge in North Dakota blocked the rule allowing Marketplace access for DACA recipients in the 19 states that had challenged the rule in court.¹ The 19 states are Alabama, Arkansas, Florida, Idaho, Indiana, Iowa, Kansas, Kentucky, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, South Carolina, South Dakota, Tennessee, Texas, and Virginia. As a result of the ruling, DACA recipients’ ability to enroll in coverage through the Marketplace “has been placed on hold in the 19 states that are involved in the lawsuit” and “the Marketplace is reviewing the court’s decision and its impact on consumers—including DACA recipients in these 19 states who already selected a QHP or planned to do so—and will issue further information shortly.”²

DACA recipients will be eligible to use the Marketplace for the first time, and able to qualify for income-based subsidies under the same eligibility rules that apply to any other applicant. As a result of this change, the government expects an additional 100,000 people to enroll in coverage for 2025.³

However, attorneys general in 19 states have filed a lawsuit in a federal district court, suing to have the DACA eligibility rule delayed and overturned. Oral arguments in that case were heard in mid-October, and it’s possible the court will issue a ruling shortly before the start of open enrollment.⁴ So there is still some uncertainty around the issue of DACA recipients’ ability to enroll in Marketplace coverage for 2025. (Update: As of Nov. 1, 2024, a ruling had not been issued in the lawsuit, and DACA recipients were able to begin enrolling in Marketplace coverage.)

Georgia switches to state-run Marketplace platform

Georgia will be operating its own Marketplace (exchange) platform this fall. Starting Nov. 1, residents will use Georgia Access – or an approved enhanced direct enrollment entity⁵ – to enroll in or renew coverage for 2025. Georgia residents have used HealthCare.gov for enrollment since 2014 but will no longer be able to use that platform to shop for 2025 coverage and subsequent years.

State-funded health insurance subsidies change in several states

In addition to the ACA’s federal premium subsidies and cost-sharing reductions, several states offer additional state-funded subsidies that further offset enrollees’ premiums, out-of-pocket costs, or both.

For 2025, there are some changes to these subsidies:

• California: A state program that debuted in 2024 eliminated deductibles and other out-of-pocket costs for applicants with household incomes up to 250% of the federal poverty level (FPL).⁶ For 2025, the program is expanding. All Covered California applicants will be eligible for plans that have zero deductibles and reduced out-of-pocket costs.⁷⁸
• New Mexico: State out-of-pocket assistance (SOPA) benefits are being expanded so that plans with 90% actuarial value (equal to a Platinum plan) will be available to enrollees with household income up to 400% of FPL.⁹ In 2024, the income limit to qualify for these 90% actuarial value plans was 300% of the federal poverty level.¹⁰
• Colorado: In 2024, Colorado’s state-funded cost-sharing reductions are available to enrollees with household income up to 250% of FPL. For 2025, the eligibility limit will be reduced to 200% of FPL, meaning fewer people will qualify. Applicants with household incomes up to 250% FPL will continue to be eligible for federal cost-sharing reductions, but applicants with income between 200% and 250% FPL will qualify for only the federal benefit, not the state-funded cost sharing reduction.¹¹
• New York: State-funded Marketplace subsidies are not currently available, but New York has received federal permission to offer state-funded subsidies starting in 2025.¹² and ¹³ Under the terms of the state’s approved waiver amendment, applicants with income up to 400% of FPL will be eligible for new cost-sharing reductions, as well as additional cost-sharing assistance for diabetes care and pregnancy/postpartum care.¹⁴

Some Oregon enrollees may switch to Basic Health Program

Oregon debuted a Basic Health Program – Oregon Health Plan Bridge – in July 2024. Adults who earn more than 138% of FPL but not more than 200% of FPL are eligible to enroll.

Read our overview of Basic Health Programs.

Marketplace enrollees in that income range had the option of switching to Oregon Health Plan Bridge starting in July 2024, but were not required to do so.¹⁵

If these enrollees make any updates to their application (including changes to contact information, projected income, address, family size, a plan change made during open enrollment, etc.), their eligibility for Oregon Health Plan Bridge will be determined at that point. If they’re eligible for Oregon Health Plan Bridge, they will no longer be eligible for Marketplace subsidies.¹⁶

So a person who updates their Oregon Marketplace account during open enrollment with a projected income in the range that’s eligible for Oregon Health Plan Bridge will generally find that moving to that coverage is their best option for 2025, as they would otherwise have to pay full price to keep their private Marketplace plan.

A person who lets their plan auto-renew without making any changes to the application can potentially keep their Marketplace plan through 2026 (instead of switching to Oregon Health Plan Bridge) but the state notes that if an enrollee experiences any changes – such as a change in income – they are required to update their application.¹⁶

Individual and family premium increases average 6-7%

The insurers that offer individual/family health coverage have proposed overall average rate increases in the range of 6% to 7% for 2025. (The semi-weighted average is about 6.1%,¹⁷ and the median is about 7%.)¹⁸ You can see specific details for carriers in your state by selecting your state on this map.

But it’s important to understand that average rate changes are calculated based on full-price (unsubsidized) premiums, and most enrollees don’t pay full price. As of early 2024, 93% of Marketplace enrollees nationwide were receiving premium subsidies that offset some or all of the cost of their coverage.¹⁹

If you’re receiving a subsidy, the net (after-subsidy) premium you pay in 2025 will depend on how much your own plan’s premium changes, but also on how much the benchmark (second-lowest-cost Silver) plan premium changes because the cost of the benchmark plan is the basis for the amount of the premium subsidy. For 2025, average benchmark premiums in states that use HealthCare.gov are increasing by 3%,²⁰ but there’s a lot of variation from one state to another. You’ll want to carefully review the notifications you receive from your insurer and the Marketplace to understand how your net premium will change if you renew your current coverage.

At least 19 states will see carrier entries or exits

As is the case every year, there will be some changes for 2025 in terms of which insurers offer Marketplace coverage in some states. In most states, the list of participating Marketplace insurers is the same for 2025 as it was for 2024. But in some states, new insurers are joining the Marketplace, while other states will see insurers exiting the Marketplace or leaving the individual market altogether.

We have details about 2025 insurer participation and premium changes on the pages we maintain for each state’s Marketplace, but here’s a summary of what we’re seeing in terms of carriers entering and exiting the Marketplaces for 2025:

Entries:

• UnitedHealthcare – entering Indiana, Iowa, Nebraska, and Wyoming²¹
• HAP CareSource – entering Michigan²²
• WellSense – entering New Hampshire²³
• WellPoint – entering Texas, Florida, and Maryland²⁴
• Simply Healthcare Plans, Inc. – entering Florida²⁵
• Ambetter/Iowa Total Care – entering Iowa²⁶
• Antidote Health – entering Arizona²⁷ and Ohio²⁸
• InStil Health – entering South Carolina²⁹
• Alliant Health Plans – entering Tennessee³⁰

Exits:

• Celtic – leaving Indiana Marketplace (will still offer plans outside the Marketplace)³¹
• Ascension (US Health & Life) – exiting Indiana, Kansas, Tennessee, and Texas³²
• Cigna – exiting Pennsylvania,³³ South Carolina,³⁴ and Utah³⁵
• Ambetter/Western Sky – exiting New Mexico³⁶
• PacificSource – exiting Washington³⁷
• Medica – exiting Arizona²⁷ and Illinois³⁸
• Aetna Life – exiting in Virginia (Aetna Health will continue to offer plans)³⁹⁴⁰

If your current insurer will be exiting your market at the end of 2024, you’ll need to select a new plan for 2025. You’ll have until Dec. 31 to pick a new plan with a Jan. 1 effective date.⁴¹ Depending on where you live, the Marketplace will likely automatically select a replacement plan for you if you don’t pick your own new plan. But it’s better to take an active role in picking your coverage.

Changes in insurer participation in the Marketplace obviously affect the plan options that are available to applicants, but they can also affect the benchmark plan premium – if the new or exiting insurer holds that position. Changes in the benchmark plan premium will affect premium subsidy amounts for everyone in that area who qualifies for subsidies, since subsidy amounts are calculated based on the cost of the benchmark plan.

New short-term health insurance rules affect access to coverage

As of Sept. 1, 2024, consumers can no longer buy short-term health insurance with total durations longer than four months, including renewals, and non-renewable plans are capped at total durations of three-months.

From late 2018 through August 2024, federal rules permitted the sale of short-term health policies with total durations of up to three years. For people who have been relying on these longer-term short-term health plans, it’s important to understand what’s available during the open enrollment period for 2025 health coverage, and the potential consequences of letting open enrollment go by without selecting a new plan.

If your current short-term policy is scheduled to terminate at some point in 2025, you will not be able to purchase another longer duration short-term policy at that point. All available policies will be capped at no more than four months in total duration, which might mean that you’ll be uninsured at some point in 2025. And the termination of a short-term policy is not a qualifying life event that would trigger a special enrollment period and allow you to enroll in an individual/family health plan at that point.⁴²

So if you’re currently enrolled in a short-term policy that will terminate in 2025, consider your Marketplace options during the upcoming open enrollment period. If you sign up for a Marketplace plan, it will provide coverage throughout 2025, and you may find that you’re eligible for federal or state financial assistance with the premiums.

Rules prevent unauthorized enrollments and plan changes

Over the last several months, CMS (the Centers for Medicare & Medicaid Services) has been taking steps to curb unauthorized enrollments and plan changes that were happening in states that use the federally run Marketplace (HealthCare.gov).

Starting in July, CMS implemented new rules that prevent brokers from adding themselves to a person’s HealthCare.gov account without the policyholder’s permission.⁴³ (Unscrupulous brokers who did this in the past were able to get paid commissions for those accounts, and could make plan changes without the enrollee’s knowledge.)

If you want to assign a new broker to your account, you’ll either need to participate in a three-way call with the Marketplace call center and your new broker, or you’ll need to log into your HealthCare.gov account and add the new broker’s information.⁴³ (Here’s how to do that.) This protocol is necessary if you want to switch from one broker to another, or if you were previously navigating the enrollment process on your own and you’ve decided you’d like a broker to help you.

Marketplace call center volume increases significantly once open enrollment is underway. So if you know that you’ll want to add a broker to your existing HealthCare.gov account or switch to a different broker – and you’re planning to utilize the three-way call to do so – you may want to address that issue before open enrollment begins.

If you’re in a state that runs its own Marketplace (meaning you don’t use HealthCare.gov), the Marketplace will have its own rules for adding a new broker to your account. The process varies from one state-run Marketplace to another, but your broker or the Marketplace will be able to explain what steps you’ll need to take if you want to add a new broker to your account.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.

1. ”State of Kansas et al. (plaintiffs) vs. United States of America et al (defendants)” United States District Court for the District of North Dakota. Ruling issued Dec. 9, 2024 ⤶
2. ”Recent court decisions impacting the Marketplace” HealthCare.gov. Dec. 10, 2024 ⤶
3. “Clarifying the Eligibility of Deferred Action for Childhood Arrivals (DACA) Recipients and Certain Other Noncitizens for a Qualified Health Plan through an Exchange, Advance Payments of the Premium Tax Credit, Cost-Sharing Reductions, and a Basic Health Program” Federal Register, May 8, 2024 ⤶
4. “Lawsuit Threatens Efforts To Extend Health Care To DACA Recipients” Health Affairs. Sep. 19, 2024 ⤶
5. “Enhanced Direct Enrollment Partners” Georgia Access. Accessed Sep. 23, 2024 ⤶
6. “Covered California to Launch State-Enhanced Cost-Sharing Reduction Program in 2024 to Improve Health Care Affordability for Enrollees” CoveredCA. July 2023. ⤶
7. “Covered California Policy and Action Items” Covered California Board Meeting. May 16, 2024 ⤶
8. “Covered California’s Rates and Plans for 2025: The Most Financial Support Ever to Help More Californians Pay for Health Insurance” Covered California. July 24, 2024 ⤶
9. “2025 Plan Year Health Insurance Marketplace Affordability Program, Policy and Procedures Manual” New Mexico Office of the Superintendent of Insurance. April 26, 2024 ⤶
10. ”2024 Plan Year New Mexico Health Insurance Marketplace Affordability Program FAQ for Issuers” NM Office of the Superintendent of Insurance. May 10, 2023 ⤶
11. “Colorado Health Insurance Marketplace Affordability Fact Sheet” Community Catalyst. April 2024. ⤶
12. “Section 1332: State Innovation Waivers – New York” CMS.org. Accessed Sept. 25, 2024 ⤶
13. “Approval letter from CMS” Centers for Medicare & Medicaid Services. Accessed Sep. 25, 2024 ⤶
14. “Section 1332: State Innovation Waivers – New York” and “Approval letter from CMS” Centers for Medicare & Medicaid Services. Accessed Sep. 253, 2024 ⤶
15. “Oregon Health Plan (OHP) Bridge Frequently Asked Questions” Oregon Health Authority. May 3, 2024 ⤶
16. “Oregon Health Plan (OHP) Bridge Frequently Asked Questions” (Page 8/9) Oregon Health Authority. May 3, 2024 ⤶ ⤶
17. “State By State: Avg. Preliminary *Unsubsidized* 2025 ACA Rate Changes: +6.1% nationally” ACA Signups. Sep. 24, 2024 ⤶
18. “Marketplace Insurers are Proposing a 7% Average Premium Hike for 2025 and Pointing to Rising Hospital Prices and GLP-1 Drugs as Key Drivers of Costs” KFF.org. Aug. 5, 2024 ⤶
19. “Effectuated Enrollment: Early 2024 Snapshot and Full Year 2023 Average” CMS.gov, July 2, 2024 ⤶
20. ”Plan Year 2025 Qualified Health Plan Choice and Premiums in HealthCare.gov Marketplaces” Centers for Medicare & Medicaid Services. Oct. 25, 2024 ⤶
21. ”New 2025 Individual Exchange plans and prior authorization information” UnitedHealthcare. Oct. 1, 2024 ⤶
22. “Health Alliance Plan and CareSource to Partner in Michigan” HAP.org. Feb. 21, 2023 ⤶
23. “New Product Highlights Remarkable Growth and Stability in New Hampshire’s Health Insurance Market” New Hampshire Insurance Department. Aug. 14, 2024 ⤶
24. “2025 Open Enrollment for health insurance” WellPoint. Accessed Sep. 23, 2024 ⤶
25. “Individual PPACA Market Monthly Premiums for Plan Year 2025” Florida Office of Insurance Regulation. Aug. 28, 2024 ⤶
26. ”Ambetter Health Expands Health Insurance Offering into Iowa in 2024” Centene Corporation. Oct. 2, 2024 ⤶
27. ”Individual and Small Group ACA Health Insurance Rate Changes” Arizona Department of Insurance and Financial Institutions. Sep. 16, 2024 ⤶ ⤶
28. ”Ohio SERFF Filing AHPO-134256597″ Ohio SERFF. Accessed Oct. 28, 2024 ⤶
29. ”Individual Market Open Enrollment for 2025 Plans” South Carolina Department of Insurance. Oct. 17, 2024 ⤶
30. ”TDCI Offers Consumer Insurance Tips for 2025 ACA Open Enrollment” Tennessee Department of Commerce and Insurance. October 31, 2024. ⤶
31. “Indiana 2025 ACA Filings” Indiana Department of Insurance. Accessed Sep. 23, 2024 ⤶
32. “APC withdrawal in 2025” Ascension Personalized Care. Accessed Sep. 20, 2024 ⤶
33. “Health Insurance Plans in Pennsylvania” Cigna. Accessed Sep. 23, 2024 ⤶
34. “Health Insurance Plans in South Carolina” Cigna. Accessed Sep. 23, 2024 ⤶
35. “Health Insurance Plans in Utah” Cigna. Accessed Sep. 23, 2024 ⤶
36. ”2025 Qualified Health Plan Information” (only four insurers are approved for 2025, and Ambetter/Western Sky is not among them) New Mexico Office of the Superintendent of Insurance. Accessed Oct. 16, 2024 ⤶
37. “PacificSource lays off 29, will largely pull out of Washington” The Lund Report. Mar. 28, 2024 ⤶
38. ”Affordable Care Act (ACA) – Illinois Rate Filings” Illinois Department of Insurance. Accessed Oct. 16, 2024 ⤶
39. “Virginia Rate Review Submissions” RateReview.HealthCare.gov. Accessed Sep. 23, 2024 ⤶
40. “ACA Rate & Form Filing Information; 2025 Presentations” Virginia State Corporation Commission. Aug. 22, 2024 ⤶
41. “45 CFR 155.420(b)(2)(iv)” Code of Federal Regulations. Accessed Sep. 23, 2024 ⤶
42. “Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage” Departments of the Treasury, Labor, and Health & Human Services. April 3, 2024 ⤶
43. “CMS Statement on System Changes to Stop Unauthorized Agent and Broker Marketplace Activity” Centers for Medicare & Medicaid Services. July 19, 2024 ⤶ ⤶