How did the 2025 Marketplace Integrity Rule change Marketplace enrollment?

What is the Marketplace Integrity and Affordability Rule?

The Trump administration proposed the Marketplace Integrity and Affordability rule in early 2025, citing the need for new standards to ensure the integrity of the Marketplaces – including safeguards to protect consumers from improper enrollments.¹ The proposed rule drew more than 26,000 public comments.²

The final rule’s effective date was August 25, 2025,² with some of the rule’s provisions taking effect immediately on that date. Other provisions were applicable for the 2026 plan year or the 2027 plan year.

Which of the rule’s provisions were implemented?

1. Elimination of the special enrollment period for low-income individuals

Who’s affected: This applies nationwide, meaning low-income people no longer have year-round access to enroll in Marketplace plans.²

The Marketplace Integrity rule called for the removal of the low-income SEP only through the end of 2026, but H.R.1 (known as the “One Big Beautiful Bill”) eliminated it permanently.³

Rationale for rule: HHS stated that the low-income SEP played a significant role in allowing fraudulent enrollments that made headlines in 2024,² and was potentially resulting in adverse selection, with people waiting until they were sick to enroll in coverage.²

2. DACA recipients are no longer eligible for Marketplace or Basic Health Program coverage

Who’s affected: HHS estimated that 10,000 DACA recipients would lose Marketplace coverage as a result of this rule, and 1,000 people would lose Basic Health Program (BHP) coverage.²

What changed: Deferred Action for Childhood Arrivals (DACA) individuals who were enrolled in the Marketplace were disenrolled as of August 25, 2025.² Under the same rule DACA recipients also became ineligible for BHP coverage because they are no longer considered “lawfully present” for the purpose of accessing Marketplace or BHP coverage. (Only four states operate BHPs: Minnesota is using state funds to continue to provide BHP coverage to DACA recipients,⁴ and two of the other three are using state funds to provide alternative coverage.)

3. Higher maximum out-of-pocket limits

Who was affected: All Marketplace plan enrollees.

What changed: Starting in 2026, the new rule finalized a methodology change for how maximum out-of-pocket limits are calculated. The result is that the highest allowable out-of-pocket limit for a single individual was $10,600 in 2026,² and grew to $12,000 for 2027.⁵

Under the previous methodology, the Biden administration had finalized a 2026 maximum out-of-pocket limit of $10,150, but that was replaced by the higher limit calculated under the new methodology.²

Impact: Higher out-of-pocket costs and less generous premium subsidies. Because the IRS uses the same premium indexing methodology to determine the percentage of income that Marketplace enrollees pay in after-subsidy premiums, the new methodology has also reduced premium subsidies. This is because it increases the percentage of income that people pay in after-subsidy premiums.²

4. Bronze-to-Silver auto-renewal banned

Who was affected: Marketplace enrollees with Bronze plans who were eligible for cost-sharing reductions (CSR) and let their coverage auto-renew.

What changed: The rule permanently removed an auto-renewal protocol that HealthCare.gov adopted in 2024, allowing the Marketplace to switch a consumer from a Bronze plan to a Silver plan in some circumstances.

Impact: Enrollees miss out on CSR unless they take action.

Details: Previous guidance directed that if an applicant was eligible for CSR, enrolled in a Bronze plan, and a Silver plan was available in the same product (HMO, PPO, etc.), with the same provider network, and with equal or lesser after-subsidy premiums, the exchange could auto-renew the enrollee into the Silver plan. This allowed the enrollee to take advantage of their CSR benefits, which are only available on Silver plans.

The final rule prohibited this protocol, starting with the 2026 plan year. Instead, the auto-renewal keeps the enrollee in their existing plan if it continues to be available.²

State-run exchanges “may retain their flexibility regarding their re-enrollment hierarchies at the discretion of the Secretary of Health and Human Services.” So a state-run exchange can seek HHS approval for a different approach to auto-renewal protocols.²

Which provisions of the federal rule were overturned by a court ruling?

1. Stricter income verification for Marketplace applications

The rule would have required additional documentation of projected household income used to determine Marketplace subsidy eligibility when federal tax data were unavailable or indicated that an applicant’s income was below the federal poverty level.

Courts overturned that rule⁶ and also blocked a 2026 federal rule that called for the same income-verification requirements for 2027.⁷

2. Required payment of past-due premiums before approval of new coverage

The rule would have allowed insurers to deny new coverage to Marketplace applicants who owed them past-due premiums unless those premiums were paid. A court overturned this provision, so insurers cannot condition new coverage on payment of premiums owed for a previous policy.⁶

3. A $5 minimum premium for auto-renewed $0 premium plans

The rule would have imposed a $5 monthly premium on HealthCare.gov enrollees automatically renewed into otherwise $0-premium plans unless they confirmed or updated their eligibility information. Courts blocked the provision, and the charge never took effect.⁶

(Note: Starting with the 2028 plan year, as a result of H.R.1, Marketplace subsidies will not be available at all if a policy auto-renews without the enrollee verifying their updated income information.)⁸

4. Pre-enrollment SEP eligibility verification

The rule would have expanded requirements for HealthCare.gov applicants to prove they qualified to enroll outside open enrollment, requiring verification for at least 75% of new special enrollments. Courts blocked the change⁶ and also blocked the same rule change when HHS finalized it again for 2027. ⁷

5. Shorter open enrollment period

The rule would have shortened HealthCare.gov’s open enrollment period for 2027 coverage to November 1, 2026, through December 15, 2026, and required state-run exchanges to end enrollment by December 31. A court overturned the change,⁶ so HealthCare.gov enrollment continues through January 15, 2027. State-run exchanges may have different deadlines, and several do.