ACA Changes for 2027: What You Need to Know Before Open Enrollment

What's changing in 2027?

As covered in more detail in our broader guide to 2027 healthcare insurance changes, this year brings a genuine cluster of shifts rather than one isolated update. Enhanced premium subsidies remain expired following their December 2025 sunset, average premiums are rising for a second consecutive year, the federal out-of-pocket maximum jumped by double digits, and a new federal rule adds stricter income verification steps while eliminating a Special Enrollment Period that had previously been available to certain low-income enrollees. Each of these is covered in its own section below.

It's worth understanding these changes as a connected set rather than isolated news items, since several of them reinforce each other. The subsidy cliff's return contributed to healthier enrollees leaving the risk pool, which contributed to this year's premium increases, which in turn makes checking your actual subsidy eligibility this specific year more valuable than it would have been in a more stable year. Reading through each section below in order gives a genuinely more complete picture than any single headline about "2027 ACA changes" could capture on its own.

Premium tax credits

The enhanced premium tax credits first introduced in 2021 and extended through 2025 expired at the end of that year and remain expired for 2027. Those enhancements had eliminated the so-called subsidy cliff entirely, capping premium payments at 8.5% of income regardless of how high a household's income was. With that provision gone, the 400% federal poverty level income cliff is back: households above that threshold receive zero premium tax credit, not a reduced one. As covered in more detail in our guide to what determines health insurance cost, subsidized enrollees who remain eligible are seeing an average premium payment increase of roughly 114% compared to recent years.

Congress has debated restoring some version of the enhanced credits, and a House-passed proposal for a multi-year extension existed as of this writing, though nothing has been signed into law as of this update. This status is genuinely worth watching, since a late legislative change could meaningfully alter subsidy eligibility for 2027 after this guide was published, which is exactly why checking your own current, specific eligibility directly rather than relying solely on general guides remains the safest approach.

Marketplace premiums

ACA Marketplace premiums are rising by approximately 15% on average for 2027, according to KFF's analysis of insurer rate filings. This follows a steeper roughly 26% average increase for 2026, the steepest single-year jump in nearly a decade. A significant driver behind both years' increases is the continued absence of enhanced subsidies, which led an estimated 3 million people to leave the Marketplace, disproportionately younger and healthier enrollees who are more likely to forgo coverage once it becomes less affordable, leaving insurers pricing plans around a smaller, sicker risk pool.

Insurers exiting the Marketplace entirely in a growing number of states compounds this effect further, since fewer competing carriers in a given area generally means less pressure keeping premiums in check. Anyone shopping for 2027 coverage should expect meaningfully fewer plan choices in some regions than in past years, making it worth comparing whatever options remain carefully rather than assuming last year's plan lineup is still fully intact.

Out-of-pocket maximums

HHS confirmed the 2027 federal out-of-pocket maximum on January 29, 2026: $12,000 for an individual plan and $24,000 for a family plan, a 13.2% increase over 2026's $10,600 and $21,200. This unusually large jump reflects a revised premium adjustment methodology finalized under the 2027 ACA final rule, which now factors in individual market premium growth in addition to employer-sponsored insurance growth. Even within a family plan, each individual's own cost-sharing is capped at the $12,000 self-only limit, an "embedded" limit that applies regardless of whether the full family total has been reached.

Bronze plans

As covered in more detail in our guide to choosing a health insurance plan, Bronze plans carry the lowest monthly premiums of the standard metal tiers but also the highest out-of-pocket exposure, covering roughly 60% of costs on average. For 2027, select Bronze Marketplace plans are permitted to set an out-of-pocket maximum as high as $15,600, above the standard $12,000 federal ceiling that applies to other metal tiers. This higher allowance is specific to Bronze-tier plans and is worth checking directly against a specific plan's documents rather than assuming the standard $12,000 figure automatically applies.

Special Enrollment Periods

The 2027 ACA final rule permanently eliminates a Special Enrollment Period that had previously been available to certain low-income individuals outside the standard annual open enrollment window. As covered in more detail in our guide to getting health insurance without a job, other Special Enrollment Period triggers remain in place, including loss of job-based coverage, marriage, the birth of a child, and losing coverage due to an insurer exiting your market, each generally requiring action within 60 days of the qualifying event.

Income verification

The 2027 final rule also introduces more burdensome income and eligibility verification requirements for Marketplace applicants. Federal regulators themselves estimate this could reduce enrollment by up to 2 million people nationally, largely due to added paperwork and verification friction rather than a change in who's technically eligible, at an estimated implementation cost of roughly $1.34 billion annually. Anyone applying for 2027 coverage should expect to provide more documentation supporting their reported income than in recent prior years.

Tax-credit reconciliation

If you receive premium tax credits during the year based on your projected income, you'll reconcile that estimate against your actual income when you file your federal tax return. If your actual income ended up higher than projected, you may owe back some or all of the excess credit you received; if it ended up lower, you may receive an additional credit as part of your refund. Repayment amounts for people under 400% of the federal poverty level are generally capped at specific dollar limits based on income, but anyone above that threshold who received a credit they shouldn't have, given the cliff's return, may be required to repay the full excess amount with no cap at all.

Who qualifies for subsidies

Premium tax credit eligibility generally requires household income between 100% and 400% of the federal poverty level, U.S. citizenship or lawful presence, and not having access to other qualifying coverage such as an affordable employer plan or Medicare. For 2027, income above 400% FPL generally disqualifies a household from any premium tax credit at all, a meaningful change from the 2021-2025 rules that capped payments at a percentage of income with no upper income cutoff. Some states have introduced their own supplemental subsidy programs to help offset this for residents whose income falls above the federal cutoff, so checking both federal and state-level assistance is worth doing before assuming you don't qualify for anything.

How to prepare for 2027 Open Enrollment

• Gather your realistic projected household income for the coming year, not simply last year's tax return.
• Check your actual subsidy eligibility under the current rules before comparing plan sticker prices.
• Compare plans on premium, deductible, coinsurance, and the new $12,000/$24,000 out-of-pocket maximum together, not premium alone.
• Confirm your specific doctors and prescriptions are still covered under any plan you're considering.
• Gather documentation supporting your reported income ahead of time, given the new stricter verification requirements.
• Enroll earlier in the window rather than waiting until the final days, especially if your prior carrier has exited the market.

A licensed Apollo Health Insurance agent can run through all of these factors for you, confirming your actual subsidy eligibility and comparing your real cost across plans, at no cost to you.

Common questions about ACA changes for 2027

Have a question that isn't answered below? Our full health insurance FAQ page covers more general coverage questions.