
In this article
- Should I let my individual health insurance plan automatically renew?
- When does auto-renewal of a health plan happen?
- If I expect my subsidy to change, should I auto-renew my plan?
- Has HHS made changes to the auto-renewal process?
- By Fall 2027 auto-renewal won’t be an option for subsidized enrollees.
- Auto-renewal for catastrophic plans
- Auto-renewal might result in a loss of your premium subsidy.
- If I have an off-exchange plan or pre-ACA plan, should I let it auto-renew?
Should I let my individual health insurance plan automatically renew?
If you have a health insurance plan in the individual market, on-exchange or off-exchange, you can probably just let it renew for the coming year without doing anything during open enrollment. But this is not in most people’s best interest. It's very useful to actively compare the available plans during open enrollment, which runs from November 1 to January 15 in most states. (Starting in the fall of 2026, the open enrollment window will be shorter.)
You might decide to renew your existing coverage, or you might end up switching to a different plan. But one of the reasons the ACA's health insurance exchanges were created was to foster a sense of competition and choice, and to encourage Americans to comparison shop for their health coverage.1 You can't do that if you passively let your current coverage auto-renew.
As described in more detail below, HHS made some adjustments to the auto-renewal process starting with the 2024 plan year, but these will no longer be in use for the 2026 plan year, due to additional rule changes that were finalized in 2025. You can see federal renewal and auto-renewal protocols here, under section (j).
Obamacare subsidy calculator *
When does auto-renewal of a health plan happen?
HealthCare.gov begins to display auto-renewals in consumers’ accounts around December 16, right after the December 15 deadline for enrollees to pick a new plan with a January 1 effective date.
But the auto-renewal process begins weeks earlier, as the system transmits renewal information to insurers.2 Most of the state-run exchanges process auto-renewals on or around December 1,3 but enrollees in all states can still make a change to their coverage at least through December 15, and in some states, through December 31.
For 2018 through 2021, open enrollment ended on December 15 in most states. That meant that in most parts of the country, people couldn't make a different plan selection after they let existing coverage auto-renew, unless they had a qualifying life event that triggered a special enrollment period.
But starting with the open enrollment period for 2022 coverage, the enrollment window in most states has been extended through at least January 15. HHS noted that this was partly to ensure that people caught off-guard at the start of the new year when their coverage was auto-renewed would have an opportunity to pick a different plan.4 This could happen, for instance, if a person doesn't closely read the renewal notices they get from the Marketplace and their insurer in the fall.
In nearly all states, plan changes made after December 15, 20255 will take effect February 1, 2026, rather than January 1. (There are some states with later deadlines for a January 1 effective date.) So if a plan auto-renews and you later select a new plan in the latter half of December or in early January, you'll have your auto-renewed coverage for January, and then your new plan will take effect in February. This is why it's important to pay attention to the information that the exchange and your insurer send you in the fall, and finish whatever changes you want to make by December 15.
Starting in the fall of 2026, states that use HealthCare.gov will end open enrollment on December 15. Other states will have the option to extend the open enrollment window until as late as December 31. But all plans will take effect January 1, 2027, and there will no longer be an option for a February 1 effective date. This will make it particularly important for people to pay close attention to renewal notices during open enrollment. There will no longer be an option to switch to a different plan after the 2027 plan year has begun, unless the person qualifies for a special enrollment period.
If I expect my subsidy to change, should I auto-renew my plan?
You should expect your subsidy amount to change each year. If it decreases, auto-renewal could result in higher premiums even if your own plan's rate doesn't increase.
But for 2026, average full-price premiums are on track to increase significantly,6 and premium subsidies are expected to decrease significantly, due to the sunsetting of the subsidy enhancements that have been in place since 2021.
For people who continue to qualify for subsidies in 2026, net (after-subsidy) premiums are expected to increase by an average of 75% in 2026 due to the subsidy enhancements expiring.7 Congress could choose to extend the subsidy enhancements but had not done so as of early September 2025.
The impending expiration of the subsidy enhancements is part of the reason that gross (pre-subsidy) premiums are increasing sharply for 2026. Insurers are accounting for the expectation that many of the people who will choose to drop their coverage due to the smaller subsidies will be healthy enrollees. This will result in a sicker overall risk pool, which means higher gross premiums.8
All of these changes make it particularly important for people to carefully read the renewal notifications they receive from their plan and the Marketplace in the fall of 2025. The impending premium increases and simultaneous subsidy decreases will mean higher premiums for virtually all enrollees. Paying attention to these details before and during open enrollment will give people an opportunity to comparison shop and to switch plans if a different option will better fit their needs and budget.
It’s also important to understand how carriers entering and exiting the market can affect the plans that are available in that area and possibly the subsidy amounts available to people in that area. (Subsidy amounts are based on the cost of the second-lowest-cost Silver plan in a given area.; if that plan changes due to the entry or exit of an insurer, subsidy amounts will also change as they’ll be based on the new second-lowest-cost Silver plan’s premium.)
For example, Aetna CVS Health will no longer offer Marketplace plans in any state in 2026. Enrollees with these plans will need to pick a replacement plan during open enrollment. If they rely on auto-renewal, the Marketplace will use an algorithm to select a replacement plan, but it might not be the one that best fits each enrollee’s needs.
Has HHS made changes to the auto-renewal process?
Yes. In rules that were finalized in 2025, HHS made some important changes to the auto-renewal process, including reversing a change that had been implemented starting with the 2024 plan year. Specifically:
- The Marketplace will no longer be allowed to switch people from Bronze to Silver coverage using auto-renewal. This protocol was used for two years (under rules finalized for 2024 coverage),9 in situations where a person was eligible for cost-sharing reductions (only available on Silver plans), enrolled in a Bronze plan, and there was a Silver option available with equal or lower net premiums and the same provider network and product type (HMO, EPO, PPO, etc.).
- If a person is enrolled in a plan with no net premium (meaning their subsidy covers the full cost of their plan), they won’t continue to have a $0-premium plan if they let their coverage auto-renew. Instead, their subsidy amount will be reduced so that they have a net premium of $5/month until if and when they log into their Marketplace account and verify their financial eligibility information. However, this provision was stayed by a court ruling in August 2025, pending the outcome of a lawsuit. If this provision is ultimately overturned by the outcome of the lawsuit, it will never take effect.10
By Fall 2027 auto-renewal won’t be an option for subsidized enrollees
Under the ”One Big Beautiful Bill” that was enacted in 2025, auto-renewal will effectively cease to be available starting with the open enrollment period in the fall of 2027, for coverage effective in 2028.11
At that point, subsidies will no longer be available if the enrollee’s eligibility information isn’t verified and updated each year. The coverage itself will still be able to auto-renew, but the elimination of subsidies during the auto-renewal process will effectively end the auto-renewal process that’s currently used by millions of enrollees each year.12
Auto-renewal for catastrophic plans
For 2025 and future years, HHS finalized a change in how automatic re-enrollment is handled when a person has catastrophic coverage and will no longer be eligible for that plan in the coming year.13 Under pre-2025 rules, there was no mechanism for the exchange to automatically select a replacement plan for a person with catastrophic coverage if the person will no longer be eligible for a catastrophic plan in the coming year – these plans are only available to enrollees under age 30 or with a hardship exemption, which is easier to obtain as of the 2026 plan year14– or if the catastrophic plan will no longer be available (some state-run exchanges do have a protocol for this).
The new rule change allows the exchange to select a new plan in these circumstances if the enrollee doesn't select their own new plan. It will be a bronze plan in the same product (HMO, PPO, etc.) with a similar provider network. If a bronze plan isn't available, the automatic re-enrollment plan will be the lowest-cost plan in the same product with a similar provider network. As is always the case, consumers in this situation would still be able to select their own replacement plan during open enrollment.
Auto-renewal might result in a loss of your premium subsidy
Although auto-renewal is available to nearly all exchange enrollees, some caveats are particularly important for people with premium subsidies. In addition to the policy changes discussed above, regarding the loss of subsidies due to auto-renewal starting with the 2028 plan year, there are various additional caveats regarding subsidies and auto-renewal.
Details were clarified in April 2015 with CMS guidance on re-enrollments, along with a re-enrollment notice published in August 2015, and the 2017 Benefit and Payment Parameters published in early 2016. There have also been some more recent changes stemming from the COVID pandemic. Here's how the rules currently work:
- HealthCare.gov enrollees who have not provided the exchange permission to obtain updated tax return data for use in the annual subsidy eligibility determination process are eligible for auto-renewal of coverage but without subsidies. (A subsidy can still be obtained if you return to the Marketplace and verify your updated financial information). State-run exchanges can set their own rules regarding enrollees in this situation.
- Marketplace subsidies must be reconciled yearly on the enrollee's tax return.15 As of 2024, HHS finalized a rule change that called for subsidies to be terminated if the applicant had failed to reconcile their premium tax credit for two consecutive years (instead of after a single year of failing to reconcile, as was the case pre-COVID). HHS noted that this was a compromise solution designed to reduce the number of people who lose their advance premium tax credit (and usually, their health insurance) after a single year of failing to reconcile, while also preventing people from incurring large multi-year debts for erroneous premium tax credits that potentially have to be repaid to the IRS.16 But for the 2026 plan year, that rule has been changed again, reverting to the way it was before 2024. Subsidies for 2026 will not be available if the person failed to reconcile their subsidies for one year (rather than two consecutive years).17
If you're in a situation in which your subsidy will be changing for the coming year, you'll receive a notice from the exchange regarding your renewal. If that happens, it's vitally important that you communicate with the exchange to make sure that your information is updated and accurate.
If I have an off-exchange plan or pre-ACA plan, should I let it auto-renew?
If you have an ACA-compliant plan that you purchased outside the exchange, it's worth shopping again during open enrollment to see whether you'd feel better off with a plan through the exchange (or possibly with a different off-exchange plan).
The vast majority of Marketplace enrollees – 92% as of 2025 – qualify for subsidies,18 which can only be used with on-exchange plans. So it's particularly important that you comparison shop in the exchange before deciding to renew your off-exchange plan.
Premium subsidies (premium tax credits) are crucial for keeping coverage subjectively affordable for millions of people, but they're only available if you buy your coverage in the exchange. You can have the tax credit applied to your premium to reduce the amount you pay each month, or you can pay full premium and claim the whole tax credit on your tax return. But either way, you can only get the tax credit if you have on-exchange coverage. So for people with off-exchange coverage, open enrollment is a great time to reconsider whether you'd be better off with a plan through the exchange.
If your plan is grandmothered (purchased after the ACA was signed into law but before the bulk of the ACA's provisions took effect in January 2014), it may be eligible for auto-renewal or it may not, depending on where you live and what health insurance carrier you have. The same is true of grandfathered plans, which can continue to renew indefinitely, but with renewal at the discretion of the insurer.
If you've kept a grandmothered or grandfathered plan for all these years, it's important to compare your on-exchange options during the open enrollment period for ACA-compliant coverage.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written hundreds of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
- “Health Insurance Marketplaces” Centers for Medicare & Medicaid Services. Accessed Sep. 3, 2025. And “Patient Protection and Affordable Care Act, Part II—Consumer Choices and Insurance Competition Through Health Benefit Exchanges” Congress.gov. Enacted Mar. 23, 2010. And “Policy Innovations in the Affordable Care Act Marketplaces” The Commonwealth Fund. Nov. 21, 2023 ⤶
- “Federally Facilitated Exchange (FFE) Enrollment Manual” Centers for Medicare & Medicaid Services. Aug. 19, 2024 ⤶
- “Schrodinger's Open Enrollment Period Continues: 2025 OEP both down 26.5% & up 2.3% at the same time!" ACA Signups. Dec. 4, 2024 ⤶
- “Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond” Centers for Medicare & Medicaid Services. Sep. 27, 2021 ⤶
- “When can you get health insurance?” HealthCare.gov. Accessed July 21, 2025 ⤶
- “Individual Market Insurers Requesting Largest Premium Increases in More Than 5 Years” KFF.org. July 18, 2025 ⤶
- “How Much More Would People Pay in Premiums if the ACA’s Enhanced Subsidies Expired?” KFF.org. Accessed July 21, 2025 ⤶
- “Early indications of the impact of the enhanced premium tax credit expiration on 2026 Marketplace premiums” Peterson KFF Health System Tracker. June 3, 2025 ⤶
- “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2024” Centers for Medicare & Medicaid Services. Accessed July 21, 2025 ⤶
- “Memorandum Opinion, City of Columbus et al. versus Robert F. Kennedy Jr. et al” (Starting on page 25). United States District Court for the District of Maryland. Aug. 22,2025 ⤶
- “H.R.1 - One Big Beautiful Bill Act” (Section 71303). Congress.gov. Enacted July 4, 2025 ⤶
- “With Budget Reconciliation Bill Enacted, Health Care Changes Loom” Health Affairs. July 11, 2025 ⤶
- “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2025; Updating Section 1332 Waiver Public Notice Procedures; Medicaid; Consumer Operated and Oriented Plan (CO-OP) Program; and Basic Health Program” U.S. Department of the Treasury; U.S. Department of Health and Human Services. April 2, 2024. ⤶
- "Guidance on Hardship Exemptions for Individuals Ineligible for Advance Payment of the Premium Tax Credit or Cost-sharing Reductions Due to Income, and Streamlining Exemption Pathways to Coverage" Centers for Medicare & Medicaid Services. Sep. 4, 2025 ⤶
- “Premium Tax Credit – The Basics” Internal Revenue Service. Accessed Dec. 18, 2024 ⤶
- “Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2024” U.S. Department of Health and Human Services. April 27, 2023. ⤶
- “Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability” U.S. Department of Health and Human Services. June 25, 2025 ⤶
- “2025 Marketplace Open Enrollment Period Public Use Files” Centers for Medicare & Medicaid Services. Accessed July 22, 2025 ⤶