A new federal rule that shortens enrollment time on Federal Marketplaces by 32 days starts next year, November 1 through December 15 in 2026. The Marketplace Integrity and Affordability Rule, effective August 25, 2025, finalized this change. According to the Centers for Medicare and Medicaid Services (CMS) the new rule will protect consumers from improper enrollment and changes to their health coverage while strengthening the integrity of the Affordable Care Act exchanges.
NACHC, alongside Community Health Centers (CHCs) and Primary Care Associations (PCAs), commented on the proposed rule underscoring the potential impact on millions of CHC patients with Marketplace coverage. The rule emphasizes balancing program integrity with consumer administrative burdens, but advocates like the National Health Law program believe changes may cause confusion and result in coverage losses among many patients. CMS projects that between 725,000 and 1.8 million individuals to lose coverage due to this rule.
CHCs and PCAs connect patients to coverage through their Outreach and Enrollment (O&E) staff who educate and enroll individuals in insurance plans and subsidies. CHCs, however, face a $360 million cut in funding for the Federal Navigator program, which provided funding for O&E staff. The smaller and less funded O&E workforce will also have to navigate changes from the recently enacted “One Big Beautiful Bill (OBBB)” which has an estimated loss of coverage for nearly 12 million people, including individuals on Marketplace plans. CHCs have been essential in improving access to coverage, e especially during the recent Medicaid unwinding.
A federal judge recently placed a temporary stay on several of the rule’s provisions until further legal action, meaning they would not be implemented on the original August 25 date. The provisions that are currently delayed have been noted throughout the blog and in NACHC’s comparison chart.
Shorter Enrollment Periods Will Likely Cause Coverage Loss
CMS acknowledged that a longer enrollment period provides “consumers additional time to make informed choices and increase access to health coverage, while mitigating risks of adverse selection, consumer confusion, and issuer and Exchange operational burden.” A shortened open enrollment period (OEP), coupled with reductions in times someone can enroll outside the OEP (a Special Enrollment Period), will create fewer opportunities to get coverage and could lead to more uninsured patients at CHCs.
In recent years, O&E staff had until January 15 to educate and enroll patients in Marketplace coverage, which is usually done through 1:1 appointments booked in advance. Now that’s not the case. A shorter deadline means O&E staff will have less time to educate and enroll individuals.
As trusted sources of information, CHCs need to start educating patients about the new enrollment period in their own state, beginning in just a few months. Although the Federal Marketplace OEP will be shortened in 2026 to December 15, the 20 state-based exchanges may choose their own OEP parameters.
Changes for Consumers
To balance improper enrollment with ‘overall disruptions’, CMS finalized parts of the rule to only be effective in the 2026 plan year. These temporary, finalized changes are a win for consumers. A 2023 KFF survey shows that 32 percent of respondents said it was somewhat or very difficult to determine if their income qualified them for financial help. However, the temporary nature of some of these changes may cause confusion and impact consumer enrollment in health insurance. The OBBB changes may add to this confusion, as the bill includes certain Marketplace changes effective in 2026, 2027, or 2028. To help CHC patients experience fewer disruptions in their insurance coverage—which improves affordability and access to care—CHCs should educate their patients about the temporary 2026 changes that might lead to different coverage options in the future. Depending on the timing of the further legal action in the lawsuit, provisions may not begin in 2026 as planned, creating more confusion.
Verification Changes
Patients juggle multiple responsibilities, and during the insurance selection process, they may be inundated with forms that take hours to complete. This rule’s additional data and income verification requirements could pose a challenge. For example, previously, people could self-certify if the IRS did not have a tax return, but now individuals must provide evidence from ‘trusted sources’. CMS estimates that data verification would take an hour, but individuals with unstable housing or living situations may need more time to gather sufficient documentation from multiple places of work. As a result, enrollment staff will need to spend extra time to ensure individuals understand the requirements and are able to gather enough evidence to show their potential income. Due to the pending lawsuit, many of the income verification provisions have been put on pause.
Coverage Rescinded for DACA Recipients
More than 500,000 people are enrolled in the Deferred Action for Childhood Arrivals (DACA) program, which provides work authorization and deportation protection for individuals who came to the U.S. as children. In 2024, CMS expanded eligibility on the Marketplace to DACA recipients to access Marketplace coverage and tax credits. However, because of a pending lawsuit, DACA recipients in 19 states were unable to enroll in the Marketplace.
Starting August 25, 2025, DACA recipients cannot enroll in a qualified health plan (QHP) through an Exchange, Premium Tax Credit (PTC), APTC, cost-sharing reduction, or a Basic Health Plan (BHP). Additionally, the OBBB prohibits all lawfully present low-income immigrants who are ineligible for Medicaid from receiving PTCs starting January 1, 2026. In 2027, all PTC eligibility for most lawfully present immigrants (except for legal permanent residents, certain Cuban and Haitian immigrants, and people from COFA nations) will be eliminated.
CHCs should educate their staff and patients about these imminent changes, particularly if their state was not part of the lawsuit and had previously permitted DACA recipient health insurance enrollment.
CHCs are operating with thin financial margins and an increased projection of uncompensated care costs. In 2023, federal 330 grant funding accounted for only 11% of health center revenue. Insurance reimbursements help CHCs provide essential services to all patients. The O&E staff will continue their efforts to support patients in securing the right coverage.
For more details about the provisions in this rule, see NACHC’s comparison chart. Please contact Elizabeth Linderbaum, Deputy Director of Regulatory Affairs, at [email protected] with any questions.