How to Prepare for ACA Open Enrollment 2026

Key Steps and ACA Changes Every Agent Should Know

As the Open Enrollment Period (OEP) approaches, preparation is everything. With several important regulatory and market shifts coming in 2026, agents who take time now to understand the changes will be in the best position to guide their clients and retain business.

Here’s what you need to know to get ready — and what’s changing for Plan Year 2026 (PY2026).

Step 1: Complete Your FFM Certification

If you plan to sell Affordable Care Act (ACA) Marketplace coverage, you must complete your PY2026 Federally Facilitated Marketplace (FFM) Certification. This training is available now — and completing it early gives you access to valuable free CEUs.
👉 Click here to complete FFM certification and earn CEUs

Step 2: Contract with ACA Carriers in Licensed States

Make sure you’re contracted with ACA carriers in every state you’re licensed to sell. Carrier availability can change year to year, and having multiple options allows you to better serve your clients — especially those who may face premium increases or plan exits.

Step 3: Diversify with Alternative Products

Not every client will find ACA coverage affordable in 2026, especially with upcoming subsidy changes. Be ready to offer alternatives such as:

• Short-Term Medical (STM) plans

• Hospital Indemnity coverage

• Accident, Dental, Vision, and Critical Illness plans

These can help bridge gaps for clients who lose subsidies or face higher premiums.

PSM Ancillary Plan Options

Step 4: Align Your HealthSherpa Profile

To streamline enrollments and reporting, make sure your HealthSherpa profile is properly aligned with YourFMO using agency code E444.
👉 Click here for setup instructions

This ensures your enrollments are credited properly, your clients are tracked, and you receive real-time application visibility.

Step 5: Understand the Key ACA Changes for PY2026

The ACA landscape is shifting again — and agents need to be ready for several critical updates that will directly impact client conversations and plan eligibility.

1. Expiration of Enhanced Premium Subsidies

What’s Ending: COVID-era subsidy enhancements are set to expire unless Congress renews them.
Impact: Many consumers will see higher premiums or lose coverage. Prepare clients early, and explore alternative solutions like Short-Term Medical, Hospital Indemnity, Catastrophic, or ancillary products.

2. Stricter Income Verification Requirements

What’s Changing: Clients with $0 premium plans must verify income annually to maintain subsidies.
Impact: Passive renewals will no longer be enough. If clients fail to verify, they could lose their subsidy or owe repayment. Agents must proactively remind clients to complete verification each year.

3. Catastrophic Plan Expansion

Change: Consumers both below 100% FPL and above 400% FPL will qualify for hardship exemptions, granting access to low-cost catastrophic coverage.
Impact: This gives agents new ACA marketplace options for clients priced out of traditional plans.

4. Elimination of Low-Income SEP

Change: The year-round Special Enrollment Period for individuals under 150% FPL may be discontinued.
Impact: These clients must enroll during OEP or risk going uninsured for the year. Agents should prioritize outreach to these households early.

5. Carrier Landscape Shifts

Example: Aetna is exiting the ACA marketplace.
Impact: Proactively contact affected clients to transition them to new plans and prevent coverage gaps. Review state-by-state carrier changes to stay ahead.

6. HSA Eligibility Expansion

New Option: Bronze and Catastrophic plans will become HSA-eligible starting in 2026.
Impact: Agents can promote HSAs as a tax-advantaged way to save for medical expenses. Clients may need to set up HSAs independently through a bank or HSA administrator.

7. Tighter Program Integrity Rules

Includes:

• Pre-enrollment SEP verification

• Removal of auto-renewal for certain CSR-eligible clients

• Revised eligibility redeterminations

Impact: Compliance accuracy will be more critical than ever. Double-check application data and educate clients about documentation requirements to avoid subsidy repayment or loss of coverage.

8. Changes to the “Lawfully Present” Definition

Update: DACA recipients will no longer be considered “lawfully present” for ACA eligibility.
Impact: Agents must be aware of this change when advising immigrant clients and ensure eligibility is verified before applying.

Final Thoughts

The 2026 plan year marks one of the biggest ACA shifts since 2021. As subsidies tighten and verification rules strengthen, proactive communication and diversification will separate successful agents from the rest.

Stay ahead by completing certification early, keeping your contracts current, and aligning with partners who can support you through these changes.

Preparation now means smoother enrollments, happier clients, and stronger retention this OEP.

PSM ACA Health Plan Options