Newsletter

WHY 2026 ACA BROKER REGISTRATION AND 2026 PLAN ANNOUNCEMENTS HAVE BEEN DELAYED

Navigating the Lag in Certification and Carrier Communication

As the 2026 Open Enrollment Period approaches, both brokers and those eligible for ACA plans are facing an unusual bottleneck: delays in both Federally Facilitated Marketplace (FFM) certification for brokers and carrier announcements regarding 2026 ACA plans. These setbacks are more than administrative hiccups—they reflect deeper regulatory shifts, system upgrades, and market recalibrations that are reshaping how brokers and policyholders can prepare for the season.

CMS Agent Certification

FFM certification (which qualifies agents to sell plans on the federal marketplace) has been delayed. Certification (the marketplace refers to this as “registration”) normally occurs in July or August but the date for certification did not start until September 22.

• The delay was primarily due to the fact that at least one Federal court has issued injunctions against certain aspects of the new affordability and integrity regulations. Other requirements have been changing constantly, many carriers are re-evaluating plans and coverage areas, and healthcare.gov had trouble keeping up with the changes and reflecting them in the final training.

Carrier Retrenchment and Strategic Delays



Many insurers are reevaluating their ACA participation due to:

• Risk adjustment recalibrations.
• State-level regulatory changes.
• Uncertainty around subsidy structures and cost-sharing protections.

As a result, carriers are delaying plan filings or pulling back from certain counties, making it difficult for CMS and marketplaces to finalize offerings. This has a ripple effect:

• Brokers can’t preview plan designs or pricing.

• Outreach materials and quoting tools remain incomplete.

• Clients face longer wait times for renewal guidance.

Regulatory Complexity and Legal Rulings

Recent federal and state court decisions—particularly around benefit mandates, AI use in coverage decisions, and anti-discrimination provisions—have forced CMS to revise guidance mid-cycle.

• These legal shifts require insurers to refile or amend plan documents.



• CMS must approve these changes before releasing final plan data to brokers.

Broker Oversight and Compliance Tightening

CMS (Medicare) is also tightening oversight of broker conduct and training compliance:

• Updated MLMS (Medical Learning Management System) profiles are now mandatory for brokers to be considered “ready-to-sell.”

• Brokers must complete recertification and attest to new standards around consumer protection, marketing ethics, and data handling.

This added layer of scrutiny slowed the rollout of certification portals and delayed the “Intent to Sell” process in the marketplaces.

FLORIDA’S 2026 ACA LANDSCAPE: PREMIUMS SURGE, COVERAGE SHIFTS

What Brokers and Consumers Need to Know Before Open Enrollment

Florida—home to the nation’s largest ACA Marketplace enrollment on healthcare.gov—faces a turbulent year ahead as 2026 Affordable Care Act (ACA) plans roll out. With over 4.5 million Floridians relying on Marketplace coverage, the latest projections signal steep premium hikes, regional disparities, and policy-driven disruptions that could reshape access and affordability.

Double-Digit Premium Increases Across the State

According to the Florida Office of Insurance Regulation, monthly premiums for individual ACA plans are set to rise sharply in 2026, with some counties seeing increases of 80–100% compared to 2025 rates.

• A 28-year-old in Duval County earning $35,000 may pay $281/month for a silver plan—up from $149.

• A family of four in Miami-Dade earning $85,000 could see premiums jump to $1,019/month after subsidies—up from $558.

• Premiums in rural counties are expected to be high: Okeechobee County is projected to have the highest premiums in the state in 2026.

These figures reflect approved filings for both on- and off-exchange plans, and they underscore the growing affordability gap in rural regions.

Why Are Rates Rising?

Several factors are driving the surge:

• Expiration of Enhanced Subsidies: The enhanced premium tax credits introduced in 2021 are set to expire at the end of 2025, leaving many enrollees with higher out-of-pocket costs.

• “Big Beautiful Bill” Fallout: The 2025 Budget Reconciliation Act—nicknamed the “One Big Beautiful Bill”—includes provisions that reduce Medicaid eligibility and phase out ACA cost-sharing protections.



• Rising Medical Costs: Increased demand for specialty drugs, labor shortages, and inflationary pressures are pushing insurers to file their largest rate increases since 2018.

Coverage Disruption and Uninsured Risk

A joint analysis by KFF (Kaiser Family Foundation) and the Congressional Budget Office projects that up to 730,000 Floridians could lose coverage over the next decade, with 500,000 directly impacted by ACA changes.

• The loss of subsidies and Medicaid cuts may force many into unaffordable plans or out of the system entirely.

• There will be increased client confusion and a surge in requests for eligibility reviews.

What We Should Watch For

• Carrier Exits and County-Level Changes: Several insurers are pulling back from some counties or consolidating plan offerings. Aetna is leaving the market entirely.

• Delayed Plan Announcements: CMS released 2026 FFM certification for brokers on September 22, but we are not yet aware that 2026 plans and premiums have been finally or approved, which complicates the outreach and quoting process. We now expect plans to be finalized and announced by mid-October if not earlier. However, training sessions to train brokers have been delayed; the annual meeting we attend to learn about plans has been delayed until October 24; last year this meeting was held almost a month earlier.

• Client Education Needs: With premiums rising and subsidies shrinking, clients must be proactively guided through plan comparisons and Medicaid alternatives.

Final Thoughts

Florida’s ACA market is entering a high-stakes transition. The situation demands strategic messaging, accurate forecasting, and a renewed focus on client advocacy. The numbers may be daunting—but as specialists in clarity and empowerment we have the right tools to help Floridians navigate the storm.

AVAILABLE ALTERNATIVES TO AFFORDABLE CARE ACT PLANS

As the Affordable Care Act (ACA) faces premium hikes and subsidy expirations in 2026, many Americans are exploring health coverage options beyond the exchanges. With the enhanced tax credits set to sunset at the end of 2025, millions may find ACA plans less affordable or accessible. This shift is prompting a surge in interest around non-ACA alternatives that offer greater flexibility, lower costs, and year-round enrollment.

Short-term health insurance remains a popular choice for people like freelancers, self-employed individuals, early retirees, or individuals between jobs. These plans can start as soon as the next day, last up to 3 years in states like Florida, and often allow access to broad provider networks without the constraints of ACA mandates. While they typically exclude coverage for pre-existing conditions and maternity care, they’re ideal for healthy individuals seeking temporary, budget-friendly protection.

Association plans are available to those who can successfully answer health questions. These plans offer large PPO networks and offer major medical plans as well as limited day benefit plans. 

There are two sets of plans that offer employees (healthy individuals are recruited and required and modestly paid to take periodic surveys as a condition of employment) and that offer contributory coverage. Employees receive 1099 or K-1 forms reflecting the payments they receive and as employees they're eligible to participate in plans offered by these providers.

Medical cost sharing programs are also gaining traction. These cooperatives pool members’ contributions to cover medical expenses, operating outside traditional insurance regulations. Though they don’t guarantee payment and lack ACA consumer protections, medical cost sharing appeals to those seeking community-driven, low-cost alternatives. Industry insiders expect significant growth in this space, especially as major insurers like Aetna exit ACA marketplaces. Medical cost sharing programs programs require waiting periods for pre-existing conditions to be eligible for sharing (i.e., for payment under the program) and some programs do not permit smokers to enroll.

Other options include fixed indemnity plans, supplemental coverage bundles, and expanded Health Savings Account (HSA) eligibility under the One Big Beautiful Bill Act for bronze and catastrophic level plans bought through an exchange. These alternatives allow consumers to tailor benefits to their needs, reduce reliance on taxpayer-funded subsidies, and, except in the case of plans bought through an exchange, permit year-round enrollment.

For 2026, the health insurance landscape is poised to become more fragmented—but also more customizable for those willing to navigate it strategically.

Call us on 786-970-0740 for more information about any of these alternatives and for help with enrolling.

About Paul Cholak

Paul has over forty years of benefits experience and has been Director of Employee Benefits for large companies, as well as a benefits consultant with major consulting firms. He understands the health and life insurance needs of individuals and families of all ages. He also has considerable experience in selling health and life insurance to employer groups.

He guides you through the steps of getting health and/or life insurance and is available to help you both BEFORE and AFTER you've made your purchase decision.