4 ways to approach Marketplace with subsidies still up in the air

The Open Enrollment Period for CY2026 is here.

So, you’ve probably seen the magnitude of your clients' premium hikes – whether they are eligible for subsidies or not.

Most customers probably aren’t happy with them. So, what’s an individual/family agent to do? Here are four paths you might explore:

Option one: Business as usual

Some cynics (or realists, however you’d like to define yourselves) might be reading the political situation and figure there’s no extension of enhanced premium tax credits on the way.

Sure, that might price some consumers out of the market, but there’s still plenty of help for those with incomes between 100% and 400% of FPL. And, anyone newly ineligible for a subsidy can take advantage of a new catastrophic exemption to at least secure some coverage.

If you’re in this camp, you’re likely beginning your Open Enrollment Period as usual. Time to start updating consent forms, gathering doctors and drugs, and helping customers bite the bullet and enroll.

Option two: Business as usual, plus supplemental benefits

Where there are problems, there are opportunities.

Your clients might not like their new premiums, which means they’ll likely opt for Bronze, Expanded Bronze, or Catastrophic coverage (again, go check out that new exemption).

They’ll see a little bit of premium relief – but they’ll also see a lot of exposure in deductibles and out-of-pocket maximums. The fact that those bronze and catastrophic plans will all be HSA-eligible in PY2026 may not be much consolation.

If they can stomach just a little more in premium, you can help them offset those costs with accident and critical illness policies. That will help prevent them from having to meet that $18,000 deductible all at once – and make you look like a knight in shining armor.

Option three: Explore ACA alternatives

There will undoubtedly be a portion of your clients who are priced out of the Marketplace, or may even be newly ineligible for coverage. But, they’ll still need something to protect their finances in the worst-case scenarios.

A few options to consider here:

• Short-term plans: These have seen a resurgence as the new administration has loosened length restrictions. Be careful, though – there’s often no coverage for pre-existing conditions or prescription drug coverage.
  
  
• Private comprehensive insurance- They’re hard to find, but private PPOs without coverage limits do exist. They’re medically underwritten, so they’re not an ideal fit for folks with chronic conditions, but they can do well for your healthy clients seeking unlimited coverage.
  
  
• Mini-meds: Mini medical plans cover many of the same services a comprehensive plan would (though, again, check the fine print on drug coverage). They keep premiums lower by placing usage limits on medical services – a lifetime maximum, and limiting PCP and specialist visits to the single digits. Again, they may not be an option for those who are managing one or more chronic conditions, but they can work well for healthy customers on a budget.
  
  
• Health sharing ministries: These are very much not insurance products. It’s a collection of members that pool money, with the aim of sharing the cost of the most expensive claims. They typically don’t cover routine care. And, many have a history of not paying claims made against them. Your buyers should very much beware when considering this option.

And, like ACA-compliant plans, any of these products can be paired with supplemental insurance to further protect your clients' finances.

Option four: Wait and see

You can’t do this one forever, obviously. Customers who want a January 1 effective date must enroll by December 15; those seeking a February 1 effective date must enroll by January 15.

But, as of this writing, there is a non-zero chance that Congress will come to some agreement extending or modifying enhanced premium tax credits. That could relieve at least some of the sticker shock your clients are seeing – and make enrolling more palatable.

So, you could spend all of November checking in: gathering consent, doctors, and drug lists, hoping the storm blows over. Then, you’d be running full steam ahead to help clients apply for their chosen effective dates.

Which one works for you?

Probably, there’s no one strategy here that fits like a glove. And, there are surely other ways to crack this chestnut.  Your clients making over 400% FPL may be better suited for catastrophic plans or ACA alternatives. They could also benefit from that wait-and-see approach.

Your clients who are still in that 100%-400% sweet spot may be able to confidently enroll now, albeit with a higher premium. They might look forward to some ancillary benefits to offset their out-of-pocket costs, though.