In and of itself, this wouldn't be too problematic as long as people are still ultimately enrolling in fully ACA-compliant policies and receiving ACA subsidies if they're eligible for them. Hell, one of these 3rd-party authorized web brokers even has a banner ad at the top of my website...which I only allow because this particular one only sells on-exchange ACA-compliant policies.
Covered California, the largest state-based ACA exchange for the largest state in the country, actually launched their 2019 ACA Open Enrollment Period over three weeks ago, on October 15th.
They still haven't posted any 2019 enrollment numbers, which I find rather irritating, but they did just send out the following press release regarding a promotional bus tour they're doing which highlights a couple of interesting data points:
Covered California Launches Iconic Bus Tour to Promote Enrollment and Show How “Life Can Change in an Instant”
As regular readers will recall, after three years of full 3 month Open Enrollment Periods across every state, last year the Trump Administration slashed the official Open Enrollment Period in half, down to just 6 weeks, from November 1 - January 31 down to November 1 - December 15th.
In response, most of the state-based exchanges announced that they were sticking with a longer period anyway, ranging anywhere from a 7th week all the way out to the full 3 month period, in the case of California, New York and the District of Columbia...each of which kept things going all the way through January 31st as had become the norm.
California even went one step further, passing a state law specifically mandating a 3-month Open Enrollment Period for 2018 and beyond.
Until today, I've been operating on the assumption that they'd be sticking with the November/December/January schedule which had become the default.