Complexity for the 2026 Marketplace Open Enrollment: Risks of Consumer Confusion & Coverage Loss
October 29, 2025
The upcoming 2026 open enrollment period for the Affordable Care Act (ACA) marketplaces is likely to be one of the most complex since the program’s implementation. Recent federal policy changes, ongoing litigation, and uncertainty around the extension of enhanced premium tax credits (ePTCs) are converging to create significant challenges for federal and state regulators, policymakers, and issuers. Rising premiums, expiring subsidies, and shifting federal regulations also have created an environment of significant uncertainty for consumers, navigators and brokers.
In this report, Complexity for the 2026 Marketplace Open Enrollment: Risks of Consumer Confusion & Coverage Loss, authored by Health Management Associates (HMA) and Wakely, an HMA Company, with support from the Robert Wood Johnson Foundation, explains these changes and their collective effect on costs and consumer experiences.
HMA and Wakely experts preview the analysis and the options policymakers, states, regulators, issuers, consumer advocates, and enrollment assisters, and other stakeholders can plan for to mitigate this confusion and coverage losses.
