Learning From Consumers in 2026 to Protect Marketplace Coverage in Future Years

Apr, 17, 2026

Learning From Consumers in 2026 to Protect Marketplace Coverage in Future Years

Ellen Montz, Manatt Health, Melissa Morales, GMMB, and Kyla Ellis, Manatt Health

On July 4, 2025, President Trump signed H.R.1 (P.L. 119-21), which makes dramatic changes to eligibility and how individuals enroll and stay enrolled in the Affordable Care Act Marketplaces. Two of those changes, which take effect beginning for plan year (PY) 2028, reshape the long-standing and industry-standard open enrollment process, putting eligible individuals at risk for coverage loss and creating uncertainty in the market. To help ensure eligible enrollees remain covered without disruptions to care, Marketplaces can take concrete steps this year to prepare.

H.R.1 Background

End of Auto-Reenrollment. Starting in 2027 for PY 2028 coverage, for the first time—and in a change from most insurance industry norms—subsidized enrollees must actively reverify their household income, family size, immigration status, eligibility for other coverage, and residence in order to maintain coverage, even when the information is still correct, has been previously verified, and is unlikely to change. The law emphasizes that Marketplaces can reverify eligibility information using available third-party data sources but makes clear that an enrollee must take an affirmative action to maintain subsidy eligibility. Additionally, the law requires Marketplaces to open a pre-enrollment verification window for consumers by August 1 each year to allow enrollees to begin the reverification process, if they choose to do so.

End of Advanced Premium Tax Credits (APTC) During Pending Verification. Beginning for PY 2028 coverage, an enrollee cannot receive APTC until eligibility is fully verified. Today, APTC can be provided while open verification questions are pending. These verification issues often arise from ordinary life circumstances—a mid-year income change, a recent move, or a marriage—that aren’t reflected in data sources that Marketplaces rely on for verification, which often have a significant lag [for example, projected income for PY 2026 uses Internal Revenue Service (IRS) tax return data from 2024]. Under H.R.1, while an applicant still has time to resolve verification issues, they would either receive no financial assistance or less than they would be eligible for based on their reported income.^[1]

Without mitigation, ending auto-reenrollment has the potential to drastically impact Marketplace enrollment. In PY 2025, 45% of Marketplace enrollees (10.8 million people) were automatically reenrolled. That share fell to 38% (8.8 million enrollees) in 2026—32% of Federally-Facilitated Marketplace (FFM) and 52% of State-Based Marketplace (SBM) enrollees—as consumers were more likely to actively shop, likely due to uncertainty about continuation of enhanced APTCs during open enrollment, increased news coverage about rising premiums, and Marketplace messaging to shop. This shift shows that Marketplaces can make progress in spurring consumer action, but also that a large share of people will still need to change their behavior to maintain subsidies, or to remain covered at all. On top of engaging millions of returning consumers in active reenrollment, Marketplaces will need to help all consumers minimize verification periods, since outstanding issues will prevent individuals from receiving their full subsidy. Ending APTC eligibility during verification periods will put coverage at risk for consumers who can’t afford the full undiscounted premium while awaiting verification and may deter others from enrolling at all—even when they are fully eligible for subsidized coverage.

What Can States Do Now?

The FFM and SBMs are preparing for significant changes to implement H.R.1 on a compressed timeframe. Compounding the challenge, the Centers for Medicare & Medicaid Services (CMS) has not yet issued the federal guidance needed to undertake the significant systems builds, operational changes, and consumer outreach campaigns. Every month that passes without guidance shortens the runway for SBMs to design, build, and test new verification workflows before PY 2028.

In the absence of federal guidance, there are concrete steps SBMs can take now to prepare for PY 2028 enrollment. The PY 2027 open enrollment period, beginning in fall 2026, offers a chance to build capacity, test approaches, and identify what works before the stakes rise for PY 2028. This preparation could include operational and communications pilots—spanning systems improvements, data verification enhancements, partner engagement, and population analysis on the operational side, and new messaging approaches and active-renewal campaign communications. The sections that follow explore specific opportunities in each area.

While these sections focus on preparatory actions SBMs can take, they could also inform FFM changes.

Operational Preparation:

Prepare and Perform Real-Time Analytic Capability to Scope and Segment the Affected Population to Inform Population Targeting. SBMs could invest now in new data collection and expand internal analytic capacity to more deeply understand who has historically auto-renewed, who is most likely to face data matching issues (DMIs) that delay subsidy eligibility verification, and which subpopulations (e.g., by income, language, geography, or length of enrollment) face the highest risk of losing subsidies or coverage. The output would inform and/or triage where to invest in changes for the 2028 open enrollment cycle.

Engage With Enrollment Partners and Examine How Compensation Structures Can Best Encourage Enrollment Under New Requirements. Issuers, agents, brokers, assisters, Navigators and other community partners will likely have a different and increased enrollment business cycle beginning in 2027 for PY 2028. SBMs could actively engage these partners to share policy and operational thinking, discuss how the pre-verification window can best leverage assistor workflows, share segmented enrollee data to support targeted outreach, and pilot workflows that model partner engagement with high-risk customers earlier. These partners may also be called upon to provide more hands-on active renewal support and DMI resolution under the new requirements. States could examine how agent and broker commissions and Navigator awards can be structured to offer that additional support.

Expand Third-Party Data Sources. Maximizing the use of reliable third-party data for PY 2028 can reduce the paperwork burden consumers will face in renewing their subsidized coverage. The fewer customers who hit pending-verification status, the fewer will face possible APTC loss starting in 2028. SBMs could acquire and integrate additional state and third-party data (e.g., state wage data, payroll data), including consent-based verification feeds—where consumers authorize the Marketplace to pull their information directly from these sources. Using this new information, the Marketplace can test real-time verification and front-end application prompts that catch issues before submission for launch this upcoming open enrollment.

Accelerate and Streamline DMI Resolution. Under current operations, some SBMs defer DMI resolution work until after application submission or open enrollment closes to direct limited resources to enrollment. H.R.1 places greater emphasis on preventing DMIs or minimizing their resolution timeframe. In open enrollment for PY 2027 coverage, SBMs could pilot additional ways to resolve DMIs, with the aim of creating a PY 2028 process that resolves most issues before January 1, including:

Positioning DMI resolution within the electronic application flow by prompting consumers to resolve inconsistencies in real time, during the application process.
Testing AI-enabled document processing within the application flow and through the post-application DMI-resolution process to reduce manual processing time.
Redesigning DMI notices using behavioral insights on the consumers receiving notices to improve response rates.
Trying proactive partner-led outreach to enrollees with open DMIs.

Communications Opportunities:

Many SBMs already conduct forms of message or marketing testing—running multiple ad variations, testing different creative approaches, and optimizing based on performance metrics. The 2027 open enrollment period offers an opportunity for more in-depth piloting of new approaches for how to interact with consumers when reminding them to log-in to their account, finish shopping, or submit additional documentation.

States can isolate enrollee segments (and control groups) and systematically test which messaging, channels, and calls to action drive engagement tied to active renewals. Owned channels (email, SMS, direct mail) provide direct access to enrollees and straightforward tracking. Paid media allows for testing on a broader scale. By leveraging these channels and creating message variations to test alongside general market campaigns, states can gather insights without expanding marketing budgets.

Across channels, the strategy is the same: design intentional variations and measure which approaches prompt action. Pilots could include:

By Approach

Segmentation: Use 2026 data to identify the segments that most recently auto-renewed. Consider a pilot that specifically engages a subset of the auto-renewers who are most at-risk for losing coverage. Alternately, compare them to a segment that actively renewed to understand behavioral differences.
Frequency and Timing: Test whether different segments respond better to varying communication cadences. For example, test weekly touchpoints throughout open enrollment for one segment while sending two strategically timed messages around key deadlines to another. Or test the effectiveness of a pre-open enrollment window-shopping push with one segment.

By Channels

Email or SMS Testing: Segment lists and test different subject lines, button copy, or calls to action. Track opens, clicks, and website conversions (like account sign-ins or plan shopping actions) using UTM codes (that add information to the end of a web address to track origins) to tie specific messages to specific behaviors.
Direct Mail With QR Code Tracking: Reach enrollees less likely to engage digitally by segmenting your mailing list for testing via notices, letters or post cards. Include a QR code with a clear call-to-action linking to renewal actions or specific pages. Use UTM codes to track QR scans and resulting website activity.
Paid Media Testing: Create ad groups/segments within a campaign to test different messages with different audiences—by age, enrollment history, or other characteristics. Track which combinations drive the most engagement and conversions to identify what moves different groups to action. If possible, leverage first-party data to specifically target enrollees.

To make these pilots meaningful, states should measure beyond traditional metrics (e.g., opens, clicks, impressions). Focus on conversions—how many enrollees sign in, shop, or take other renewal actions—which reveal what messaging is working.

Conclusion

H.R.1’s 2028 changes will reshape the Marketplace landscape, but SBMs are not powerless in the interim. States that use 2027 to test both operational and communications strategies will enter 2028 with something invaluable: real evidence about which systems, partnerships, and messages actually move their enrollees to act. That evidence can sharpen verification workflows, focus partner engagement, and shape outreach campaigns that meet enrollees where they are. In the absence of timely federal guidance, the work SBMs do now could be the difference between a 2028 marked by preventable coverage losses and one where SBMs successfully carry their enrollees through the transition.

[1] For example, available third-party data may be able to verify that the consumer is eligible for some APTC, but less than the amount the individual would be eligible for if their income attestation were accepted. The question of whether an individual can receive partial APTCs and how additional APTCs, based on post enrollment verification of the consumers attested income, will be delivered (during the year or at tax filing) will likely be addressed in forthcoming regulations.