ACA Open Enrollment 2025 Guide

To be able to enroll on the ACA’s Marketplace:⁹

• You must live in the United States.
• You must be a U.S. citizen or national or be lawfully present (Washington state allows undocumented immigrants to use its Marketplace, and Colorado has a separate platform that undocumented immigrants can use to enroll in coverage¹⁰).
• You must not be incarcerated.
• You can not be enrolled in Medicare coverage.

DACA recipients are allowed to use the Marketplace and obtain income-based subsidies for 2025, and could sign up for Marketplace coverage starting November 1, 2024. In December 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 court¹¹ But a preliminary stay was issued in that case the following week, meaning that DACA recipients could once again enroll in Marketplace coverage nationwide.

But HealthCare.gov notes that “If a future court decision impacts your Marketplace coverage, the Marketplace will send you a notice. This is a preliminary court decision and final decisions could affect your eligibility for coverage. Check back for updates before January 15 when Marketplace Open Enrollment ends.”¹²

Being eligible to enroll in the Marketplace is not the same as being eligible for financial assistance. In short, the income-based subsidies available through the Marketplace/exchange are reserved for people who aren’t eligible for Medicaid, zero-premium Medicare Part A, or coverage offered by an employer that’s deemed affordable and comprehensive. (Here’s how to determine whether employer-sponsored coverage is affordable to you.)

Premium subsidy rules are designed to ensure that subsidy-eligible individuals won’t pay more than 8.5% of their household income in premiums for the benchmark (second-lowest-cost Silver) plan in the Marketplace.¹³ (The percentage of household income that people are expected to pay can be much lower – as low as 0% – depending on their income.)¹³

You can use our subsidy calculator to get an idea of whether you’re eligible for premium subsidies, and if so, how much those subsidies could be.

Premium subsidies are a refundable tax credit.¹⁴ You may qualify for a subsidy based on your projected household income for the year you’ll have coverage. And then you’ll need to reconcile that with the IRS when you file your tax return for that year, based on your actual income.¹⁵

Marketplace cost-sharing reductions (CSR)¹⁶ are another type of Obamacare subsidy. CSR assistance is designed to ensure that people with low to moderate incomes can afford to receive health care services. Enrollees who qualify for CSR usually also qualify for premium subsidies.

CSR subsidies result in lower out-of-pocket costs, including lower deductibles and copays. For applicants with eligible incomes, these subsidies are automatically incorporated into all of the available Silver-level plans. But if you’re eligible for CSR subsidies and you buy a metal plan other than a Silver plan, you’ll forfeit this advantage

In addition to federal premium subsidies and CSR subsidies, some state-run Marketplaces offer their own subsidies.

No. It is unlawful for someone to sell you a Marketplace plan (or an individual/family plan outside the exchange) if you already have Medicare, even if you only have either Medicare Part A or Part B.¹⁷ So if you’re enrolled in Medicare, the Marketplace open enrollment period does not apply to you.

During the open enrollment period for 2024 coverage, enrollment reached a record high, with more than 21.4 million people signing up for coverage through the Marketplaces nationwide.¹⁸

The record-high enrollment was driven largely by the subsidy enhancements created by the American Rescue Plan (ARP) — which are still in effect for 2025 — as well as the “unwinding” of the pandemic-era Medicaid continuous coverage rule.

For 2025 coverage, several changes are applicable. You can learn more in our detailed overview of what’s new for 2025, but here’s a summary:

• DACA recipients are now eligible to use the Marketplace for the first time.¹⁹ (As noted above, this rule change was challenged in court and a judge blocked DACA recipients from enrolling in Marketplace plans in 19 states. But a preliminary stay was issued in that case the following week, allowing DACA recipients to use the Marketplace nationwide. However, this could still change in the coming weeks.¹²)
• Georgia is running its own enrollment platform. Georgia residents are not using HealthCare.gov to sign up for 2025 coverage.
• State-funded subsidies are changing in some states, including Colorado, New Mexico, California, and New York.
• There are at least 18 states where there will be changes in the insurers participating in the Marketplace, including some exits and some entries. Our detailed overview includes a full list of the Marketplace insurer changes for 2025. Insurer exits and entries can result in changing benchmark premiums, which can change premium subsidy amounts. Here’s what you need to know about how that works.
• People will no longer be able to buy short-term health insurance that lasts for more than three or four months, depending on renewability.

For 2024 coverage, several changes were applicable:

• Healthcare.gov’s automatic re-enrollment protocols changed somewhat,²⁰ to allow the exchange to move a CSR-eligible enrollee from a Bronze plan to a Silver plan, if the Silver plan would have an equal or lower premium and the same provider network and product type (HMO, PPO, EPO, etc.) as the Bronze plan. This protocol could be used regardless of whether the Bronze plan continues to be available for 2024. The idea behind this change is to maximize the benefits that enrollees can receive, but it’s still in each person’s best interest to log into their account and select their own coverage. Read why letting your individual health insurance plan automatically renew may not be in your best interests.
• In some states, new insurers joined the exchange for 2024, including Indiana, Maryland, Colorado, California, Nevada, Oklahoma, New Mexico, Utah, Pennsylvania, New Jersey, South Carolina, Wisconsin, Kansas, Ohio, and Delaware.
• In other cases, insurers left the exchange at the end of 2023. For example, Oscar Health left the exchange in California,²¹ and Cigna left the Marketplace in Kansas and Missouri.²² Piedmont Community Healthcare exited the individual market in Virginia,²³ and US Health & Life exited the Marketplace in Michigan.²⁴ One of Louisiana’s insurers was acquired by another, reducing the number of participating insurers by one.²⁵
• Some states began offering new or enhanced state-funded subsidies for 2024, including California,²⁶ Colorado,²⁷ Maryland,²⁸ Massachusetts,²⁹ and New Mexico.³⁰ Read more about states that offer their own health insurance subsidies.
• Virginia began using a new exchange platform (the Virginia Health Insurance Marketplace), instead of HealthCare.gov.³¹ (Georgia had also sought approval to operate its own state-based exchange platform, but CMS delayed Georgia’s implementation until the fall of 2024.)³²
• Medicaid expansion took effect in North Carolina on December 1, 2023. North Carolina Marketplace enrollees with income from 100%-138% of the poverty level were eligible for subsidies for private plans in 2023, but became eligible for Medicaid in 2024.³³
• Agents and brokers assisting with enrollments in states that use HealthCare.gov are now required to document that the enrollee has consented to the agent/broker’s assistance, and maintain a record of the consent on file for ten years.³⁴  The consent can be obtained via an audio recording or a written document,³⁵ and must include, at a minimum, the date, the consumer’s name, the agent/broker’s name, and an explanation of the attestations in the eligibility application.³⁶

There is no longer a penalty imposed by the federal government for being uninsured. But some states impose penalties when residents do not have health coverage or a qualifying exemption. They include:

• Massachusetts³⁷
• New Jersey³⁸
• California³⁹
• Rhode Island⁴⁰
• District Of Columbia⁴¹

In a nutshell, this author says no. Auto-renewal or automatic re-enrollment (when a plan is terminating) for the coming year’s coverage is available through the Marketplaces in every state. However, it may not be in your best interest to rely on automatic renewal. Selecting your own plan for the coming year is better than relying on auto-renewal or a Marketplace algorithm that will select a new plan on your behalf.

You’ll want to pay close attention to any notices you receive from your health plan and Marketplace, as they will let you know how your benefit details, monthly premium, and premium subsidy (if applicable) are changing for the coming year. You’ll also want to carefully compare the other options available in your area, as they may not be the same as the options that were available for this year.

You can certainly choose to select a plan and complete the enrollment process on your own, through the Marketplace/exchange website (or via an enhanced direct enrollment entity if you’re in a state that uses HealthCare.gov).⁴²

But if you prefer to have help with the process, it’s available for free online, over the phone, and from people in your community:

• Health insurance Navigators
  • Provide education and outreach about the Marketplace and available health plans, help applicants determine whether they qualify for subsidies or Medicaid, and assist in the enrollment process.
  • Can generally provide assistance after you enroll, helping with issues like eligibility appeals and how to utilize your health coverage.
  • Are funded by the Marketplace. The funding comes from the federal government in states that utilize a federally run exchange, and by the state in states that run their own exchanges.⁴³
• Certified application counselors (CACs)
  • Similar to Navigators, but their focus tends to be strictly on helping people enroll, without the more extensive assistance that some Navigators can provide.
  • The exchange designates local “CAC designated organizations” (health centers, faith-based organizations, colleges, etc.) and people who are affiliated with or employed by those organizations are eligible to serve as CACs.⁴⁴
  • CAC funding can come from a variety of state and federal sources, and CACs are often volunteering their time to help people enroll in health coverage. The Marketplace does not provide funding for CAC organization.
  • Learn more about certified application counselors.
• Insurance brokers and agents
  • Licensed by the state and certified by the Marketplace/exchange.
  • Can help consumers determine subsidy or Medicaid eligibility, and they can also make plan recommendations based on a client’s particular situation.⁴⁵ (Navigators and CACs cannot do this).
  • Provide ongoing assistance for questions and problems regarding billing, utilization, claims, and appeals.
  • Generally are required to carry errors and omissions insurance.