Hobbling towards Enrollment: My 2027 ACA Open Enrollment Guide (Part 2)

In Part 1 of my 2027 ACA Open Enrollment Guide, I covered:

• The Federal Poverty Level (FPL) household income guidelines for calendar year 2027

• The Open Enrollment Period (OEP) deadlines for every state, including exceptions/special cases

• The official ACA Exchange/Marketplaces to use to shop for & enroll in healthcare coverage

• The 2027 Advance Premium Tax Credit (APTC) household income table for calculating subsidy eligibility

• Ways to legally keep your Modified Adjusted Gross Income (MAGI) below the 400% FPL subsidy eligibility cut-off threshold, and...

• A reminder that starting this year, there's no longer any caps on what portion of those subsidies you might have to pay back if your actual MAGI ends up being higher than you anticipated.

Today I'm moving on to...

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6. IF YOU'RE ENROLLED OFF-EXCHANGE, SEE IF YOU CAN ENROLL ON-EXCHANGE INSTEAD.

As far as I can figure, up to ~2 million Americans are still enrolled in OFF-exchange, ACA-compliant individual market policies. Historically, the main reason for this has been that they didn't qualify for financial help, so they didn't see the point of filling out any additional forms by enrolling on-exchange.

The reality, however, is that even with the subsidies being severely weakened, some of these off-exchange enrollees may have been eligible for ACA subsidies after all if they had enrolled in the exact same plan but had done so via their ACA exchange instead of directly through the carrier.

With the enhanced tax credits having expired, there's a lot fewer people who benefit by moving from off-exchange to on-exchange plans, but I'd still strongly urge people to at least check into it, especially if there's any chance of your 2027 household income being being less than 400% FPL (see the table in Part 1 for how much that will be).

Full-price/unsubsidized ACA premiums are increasing by another 15% on average nationally next year, so I can't stress this enough: If you enroll off-exchange, there's a chance you'll be leaving thousands of dollars in savings on the table.

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7. MULTIPLE STATES ARE OFFERING THEIR OWN EXTRA SUBSIDIES TO MITIGATE THE DAMAGE:

CALIFORNIA:

California has had their own supplemental state-based financial assistance program for ACA enrollees for several years now, although they retooled the way it works last year in response to the expiration of the enhanced federal tax credits.

In July, Covered California, the state-run ACA exchange, announced that they’ll be expanding their existing supplemental financial assistance program to cancel out a portion of the lost federal funding:

…Gov. Newsom and the California Legislature increased the amount of state funds available for the Covered California State Subsidy Program, appropriating $300 million in Health Care Affordability Reserve Fund (HCARF), up from $190 million. As a result, Californians with incomes up to 200 percent of the federal poverty level in 2027 ($31,920 for an individual or $66,000 for a family of four) will be eligible for financial help to lower the cost of monthly premiums.

While the state subsidy program is not enough to fill the gap left by the expiration of enhanced federal subsidies, more than 500,000 Californians are projected to receive a state subsidy in 2027, about 30 percent of all enrollees. Additionally, nearly 200,000 can choose from two Silver-tier plans with a $0 premium.

…Covered California estimates the state subsidy program will open financial help to an additional 200,000 Californians who weren’t eligible in 2026 and prevent 90,000 people from dropping coverage in 2027.

The exact subsidy amounts will vary depending on the enrollee and what their circumstances are, but overall, it should look like this:

• Under 150% FPL: Avg. state subsidy is $63/month (no y/y change)
• 150%-165% FPL: Avg. state subsidy is $33/month (up from $23/mo)
• 165%-200% FPL: Avg. state subsidy is $36/month (new for 2027)

This effectively means that all enrollees earning up to 150% FPL should be eligible for $0-premium Silver plans, while the benchmark Silver plan for those earning between 150 - 200% FPL will cost 1.5% less of their household income than it would without the state subsidies in place.

COLORADO:

Last year Colorado passed emergency legislation to generate up to $100 million in funding to replace a portion of the lost federal subsidies for 2026. For 2027, they’ve passed additional legislation which extends this state assistance, although it will be at a slightly reduced rate:

Subsidy Structure for Households Below 400% FPL:

1. For the first enrollee in a household, the enhanced premium subsidy shall be the lesser of $70 per member per month (PMPM) or the premium balance after federal APTC has been applied.

2. For each additional member in the household who is subject to a premium, the enhanced premium subsidy shall be the lesser of $25 per member per month (PMPM) or the premium balance after federal APTC has been applied.

These amounts are down from $80/mo for the first enrollee and $20/mo for each additional enrollee in each household.

Colorado also has their unique “OmniSalud” program for a limited number of undocumented immigrants & DACA recipients, with some changes for 2027:

SilverEnhanced Savings: Eligibility and Lottery Information

SilverEnhanced Savings is a financial assistance program for Coloradans regardless of documentation status, funded by the Health Insurance Affordability Enterprise (HIAE). The program requires a monthly $15 premium contribution per enrollee and requires issuers to pay 73% of covered out-of-pocket costs.

To be eligible for re-enrollment in SilverEnhanced savings for 2027, applicants must:

1. Be currently enrolled in OmniSalud and receiving SilverEnhanced Savings (e.g., enrolled in a special SilverEnhanced Savings 73% plan)
2. Live in Colorado
3. Meet income requirements based on the size of household (household income < 150% FPL)
4. Not qualify for Health First Colorado (Medicaid), Child Health Plan Plus (CHP+), or Connect for Health Colorado due to immigration status

After eligible existing SilverEnhanced Savings customers re-enroll, Colorado Connect chooses recipients through a random selection process called the OmniSalud lottery.

To be eligible to enter the random lottery to receive SilverEnhanced savings for 2027, applicants must meet the last 3 requirements above.

CONNECTICUT:

The Covered Connecticut program has been in place for several years for qualifying residents who earn up to 175% FPL. CoveredCT enrollees pay literally nothing in either premiums or out of pocket expenses!

In addition, in response to the expiration of the enhanced federal tax credits, Connecticut also allocated $70 million in state subsidies for other enrollees this year which covers the full amount of lost federal tax credits for those earning 100 - 200% FPL and half of the lost federal tax credits for those earning 400 - 500% FPL. Unfortunately, as of this writing it looks like this program will not be extended into 2027.

HOWEVER, Connecticut is launching a new subsidy program specifically targeting residents who are early childhood educators:

Connecticut officials on Wednesday announced that eligible staff in the early childhood sector can now apply for a subsidy toward health insurance plan premiums, a benefit connected to the ambitious endowment created to expand and make affordable the state’s childcare and preschool network.

The subsidy will provide educators and staff employed by licensed child care centers or operating licensed family child care homes with $1,000 to $1,200 annually toward insurance premiums for plans through the state’s healthcare insurance exchange, Access Health CT. An estimated 7,200 to 8,800 early childcare workers are eligible for the program.

DISTRICT OF COLUMBIA:

While this isn’t technically a “state-based subsidy,” DC residents earning between 138 - 200% FPL are eligible for Healthy DC, the Districts Basic Health Plan program:

There are no monthly payments and no costs when you get care. All plans cover doctor visits, urgent care visits, hospital stays, prescription drugs, mental health care, and more.

I believe there’s around 15,000 DC residents enrolled in Healthy DC.

MARYLAND:

This year Maryland launched a fairly robust arrangement to backfill lost federal assistance for most enrollees:

…the state has created a new subsidy program for all ages for those who are under 400% of the federal poverty level to help offset the expiration of the enhanced federal subsidies. The state subsidy program will replace 100% of the enhanced federal subsidies for those under 200% of federal poverty level and will replace 50% of the enhanced federal subsidies for those between 200% and 400% of the federal poverty level. Those over 400% of the poverty level will not receive a state subsidy.

There was some debate earlier this year about whether to keep this program the same for 2027 or to water it down somewhat, but in the end it looks like they’re keeping the subsidy thresholds the same for a 2nd year.

Maryland also has their Young Adult Subsidy program which reduces the expected contribution for young adults 19-33 by 2.5 percentage points, phasing down by 0.5 points for each year above 33 until the young adult subsidy fully phases out at age 38. This represents a significant savings for those eligible.

MASSACHUSETTS:

Massachusetts has long had their “ConnectorCare” program in place for residents who earn up to 300% FPL. They extended this out to enrollees who earn up to 500% FPL a few years ago, but due to the expiration of the enhanced federal subsidies at the end of 2025, in practice the income cut-off is only 400% FPL.

Here’s the details on ConnectorCare:

ConnectorCare plans have $0 or low monthly premiums, low out-of-pocket costs, and no deductibles. Plus, you may be able to fill certain prescription medicines at no cost for chronic health conditions like asthma, coronary artery disease (a type of heart disease), diabetes, hypertension (high blood pressure), and opioid addiction.

ConnectorCare plans offer great coverage with important benefits like doctor visits, prescription medications, and emergency care. ConnectorCare plans have low monthly premiums, low co-pays, and no deductibles. There are different ConnectorCare Plan Types, which are based on your income. All of the plans offered for each Plan Type will have the same benefits and co-pays for covered services. You can see the co-pays for different services for 2026* in the chart found here for each Plan Type…

ConnectorCare plans are offered by some of the leading insurers in the state. Each insurer’s plan may have different doctors or hospitals in its provider network. Before you enroll, use our online tools to see if the providers you want and the prescription drugs that you need are covered in the plan’s network.

*(I assume the 2027 co-pay chart will be posted soon)

MINNESOTA:

Around 100,000 Minnesota residents with household income is up to 200% FPL are enrolled in the states expanded MinnesotaCare Basic Health Plan program.

Minnesotacare features $0 premiums for households earning up to 160% FPL and $4 - $28 premiums on a sliding scale for households earning 160 – 200% FPL. Children up to 20 years old have no cost sharing, and adults 21+ only pay $100 for ER visits and have very low co-pays for other typical services.

NEW JERSEY:

Last year New Jersey was an other state which retooled and enhanced their existing supplemental state-based subsidy program to help cancel out as much of the damage from the expiring federal funding as possible:

...The state marketplace launched in 2020 with a state subsidy – called New Jersey Health Plan Savings – to further lower monthly premiums for consumers, beyond the tax credits offered by the federal government. The Department is estimated to provide $215 million this year to support state subsidies, New Jersey Health Plan Savings, providing greater affordability in the market by lowering premiums for hundreds of thousands of New Jerseyans.

The NJ Health Savings program reduces premiums by anywhere between $20 - $100/month per enrollee depending on their household income:

• Income up to 150% FPL: $20/mo
• 150 - 200% FPL: $40/mo
• 200 - 250% FPL: $50/mo
• 250 - 400% FPL: $100/mo
• 400 - 500% FPL: $50/mo

I don’t know for certain whether this program will have any changes in 2027, but it does appear to be continuing according to this July 2026 press release from the NJ Dept. of Banking & Insurance, which states:

Despite reduced federal help, most residents enrolling through Get Covered New Jersey qualify for financial help. State subsidies, called New Jersey Health Plan Savings, are available to eligible consumers with an annual household income of up to 600 percent of the federal poverty level.

NEW MEXICO:

Unlike the other states on this list which have only been able to backfill a portion of the federal tax credits which are set to expire, last year New Mexico pulled of something of a miracle:

While it appears that Congress will allow enhanced federal Premium Tax Credits to expire, New Mexico’s Health Care Affordability Fund (HCAF) will cover the loss of the enhanced premium tax credits for households with income under 400% of the Federal Poverty Level (or $128,600 for a family of four), providing up to $68 million in premium relief for working families who enroll in coverage through BeWell in 2026. Federal and state premium assistance will continue to reduce the impact of the rate increases.

This means they're covering 100% of the lost subsidies for every enrollee under 400% FPL who currently qualifies for them...but then they went one step further and passed additional legislation which means that ALL New Mexico ACA exchange enrollees are fully protected from the expired tax credits in 2026!

What's more impressive still is that also unlike other states, NM has somehow managed to find the funding to do this without cannibalizing their existing "Turquoise Plan" supplemental subsidy program:

This program was introduced in 2023; it reduces benchmark Silver premiums for enrollees earning up to 200% FPL down to $0, while also reducing them by lesser amounts for enrollees earning between 200 - 400% FPL. It also dramatically upgrades the cost sharing reduction subsidies while rebranding Silver CSR plans as “Turquoise Plans” for easier consumer marketing.

There was some question as to whether or not New Mexico would be able to continue this extremely generous program beyond December, but sure enough, earlier this year…

The New Mexico Senate passed a bill to protect affordable health care coverage for tens of thousands of residents facing the loss of federal support, sending the measure to Gov. Michelle Lujan Grisham, who intends to sign it.

House Bill 4 increases revenue to the state’s Health Care Affordability Fund, the primary tool New Mexico uses to keep premiums manageable for working families and small businesses. The bill comes as expiring federal tax credits and Medicaid cuts threaten to price tens of thousands of New Mexicans out of coverage.

…The FY27 Executive Budget Recommendation includes funding for health care affordability programs supported by the fund. These investments would protect health coverage for up to 46,600 New Mexicans and reduce health care costs for up to 122,000 people statewide.

NEW YORK:

Like Minnesota (and more recently DC), New York has long had their own Basic Health Plan (BHP) program in place for residents earning 138 - 200% FPL, called the Essential Plan:

NY State of Health’s Essential Plan includes comprehensive benefits with $0 monthly premiums and very low-cost sharing. The Essential Plan:

• Has no deductible, so the plan starts paying for your health care right away.
• Covers comprehensive benefits, including dental and vision, inpatient and outpatient hospital care, prescription drugs and more.
• Covers free preventive care like routine exams and screenings.
• Has continuous open enrollment, meaning you can enroll at any time during the year through NY State of Health.

Eligibility:

Individuals are eligible for the Essential Plan if they are:

• New York State residents
• Lawfully present in the U.S.
• 19-64 years old
• Not eligible for Medicaid or Child Health Plus
• Not eligible for employer and other coverage
• Able to meet the Essential Plan annual income requirements

In 2024 & 2025, New York had expanded Essential Plan eligibility up the household income range to 250% FPL, which boosted enrollment significantly.

Unfortunately, due to massive funding cuts caused by the passage of H.R.1 (the so-called One Big Beautiful Bill Act, or OBBBA), as of July 2026 the state had to eliminate this expansion of the program and revert back to the original, far less robust version.

As a result of the budget cuts, a whopping 450,000 of the prior ~1.7 million BHP enrollees have been kicked off of the program.

There’s still over 1.4 million New Yorkers enrolled in it, however, and it remains an excellent option for those who still qualify.

New York has also had their own state-funded supplemental Cost Sharing Reduction (CSR) program in place for around 62,000 ACA enrollees…but those are also expiring at the end of 2026, again due to the massive budget cuts caused by OBBBA.

OREGON:

Last year, Oregon became the third state to launch a Basic Health Plan (BHP) program, dubbed the "Bridge Program," for adults earning between 138 - 200% FPL. The Bridge Program is similar to the BHP plans in DC, Minnesota and New York, and had around 43,000 Oregonians enrolled in it last time I checked.

RHODE ISLAND: (New for 2027!!)

via HealthSource RI:

For the 2027 Open Enrollment period, which runs November 1, 2026 through January 31, 2027, Rhode Islanders have a new way to save on health coverage through HealthSource RI. The Rhode Island Marketplace Affordability Program (RIMAP) provides new state financial assistance to help make health insurance more affordable. The program was created in response to the expiration of enhanced federal premium tax credits, which increased health insurance costs for many Rhode Islanders in 2026.

Starting in January 2027, RIMAP is expected to help more than 20,000 eligible current and former HealthSource RI customers afford health coverage. For many customers, RIMAP assistance will be in addition to federal tax credits. Other state affordability programs are also available, including premium assistance for eligible parents and caretakers of children enrolled in Medicaid.

You may qualify if your household income is:

• Under 200% of the federal poverty level. For example, an individual earning about $31,920 per year or a family of four earning about $64,000 per year may be eligible. OR

• Over 400% of the federal poverty level, if an average plan would cost a high percentage of your income. For example, an individual earning more than $63,840 per year or a family of four earning more than $132,000 per year may be eligible depending on age and income.

Examples:

• An individual earning $31,000 per year could save about $119 per month on health coverage, in addition to federal tax credits.

• A family of 4 earning $64,300 per year could save about $133 per month on health coverage, in addition to federal tax credits.

• A couple ages 61 and 62, earning $85,000 per year, could save about $1000 per month on health coverage.

VERMONT:

Available to Vermont residents earning up to 300% FPL, Vermont Premium Assistance is unusual in that they reduce net premiums by 1.5 percentage points...which means that some low-income enrollees are technically paying negative premiums. In reality, the "excess" subsidies just go to cover any premiums for services not covered by federal subsidies (no, you don't actually get paid for enrolling).

VIRGINIA: (New for 2027!!)

Back in July, the Virginia ACA exchange (the rather unimaginatively named “Virginia’s Insurance Marketplace”) announced that they were planning on becoming the latest state to offer their own supplemental insurance premium subsidies for ACA enrollees.

A few weeks ago, the VA Marketplace posted more detailed information on how the new $150 million in state-funded subsidies will work:

Virginia Premium Savings is a new state-funded program that helps eligible Virginians lower their monthly health insurance premiums. It’s applied on top of any federal premium tax credits you may already qualify for. Your exact savings depend on your income, household size, and the plan you choose.

New savings don’t apply automatically. You’ll need to enroll to receive them. For most Virginians, open enrollment (November 1, 2026 – January 29, 2027) is the only chance to get the savings on a plan this year, so don’t wait.

You may be eligible for Virginia Premium Savings if:

• You live in Virginia
• You enroll in a health plan through Virginia’s Insurance Marketplace
• Your household income is between 138% and 250% of the federal poverty level
  • 250% FPL will be up to $39,900 for 1 person & up to $82,500 for 4 people

…Consumers who are eligible to receive Advance Premium Tax Credits must do so to receive Virginia Premium Savings. However, if you are ineligible for APTCs, you may still qualify for Virginia Premium Savings.

There’s also a recent Richmond Times-Dispatch article with more specifics:

...The state subsidy translates to $65 per covered person per month for households earning between 138% and 150% of the federal poverty level, and $90 per person per month for households earning between 150% and 250% of the poverty level, Patchett said.

For a family of four earning no more than $49,500, or 150% of the poverty level, the subsidy amounts to a $260 a month savings on premiums.

The state subsidy amounts to $90 per person per month for modestly better-off households, so for a family of four with an income of $82,500, the subsidy amounts to a monthly saving of $360.

...The enhanced credits were aimed at reducing [net premiums] to between 0% and 4% of income for the households that will be getting the Virginia credit.

...The state exchange found the group hardest hit by the end of the enhanced federal credit were households with income below 150% of the poverty level: 52,500 dropped coverage since the start of enrollment for coverage this year, the first without the enhanced credit or the state subsidy. Another 36,200 with incomes up to 250% of the poverty level also dropped coverage.

But only 7,300 households with incomes about 400% of the poverty level — the group that lost the enhanced credit and that never had the original credit — dropped coverage.

WASHINGTON STATE:

Cascade Care Savings are available for enrollees earning less than 250% FPL who enroll in Silver or Gold “Cascade Care” plans (Cascade Care plans are Washington’s quasi-”public option” ACA policies). This further reduces net premiums down to as low as $0/month; most pay $10/month or less. Cascade Care plans have deductibles/co-pays around $1,000 lower than non-Cascade Care Silver plans.

There are some changes to the program next year, however:

In 2027, the maximum Cascade Care subsidy is $35/month for enrollees with income up to 200% FPL, and $20/month for those with income between 210% and 250% FPL…

For those who don’t get federal subsidies but whose income isn’t more than 250% FPL, the maximum Cascade Care subsidy is $185/month in 2027.

Cascade Care subsidy amounts decreased for 2026 and again for 2027. For 2026, Cascade Care Savings subsidy amounts for enrollees who qualified for federal subsidies were smaller than they were in 2025 ($55 per member per month, down from $155 per member per month in 2025). But due to the state’s new premium alignment approach (silver loading), more affordable Gold plans became available to enrollees who qualified for federal premium subsidies, even with the smaller Cascade Care Savings and the expiration of the federal subsidy enhancements.

For those who didn’t qualify for federal premium subsidies in 2026 (but whose income was no more than 250% of FPL) Cascade Care Savings remained at $250 per member per month, the same as they were in 2025. As noted above, that benefit is capped at a maximum of $185/month in 2027.

That's it for Part 2. Stay tuned for Part 3 of my 2027 ACA Open Enrollment Period Guide coming soon…