Recently, CMS released its proposed Notice of Benefit and Payment Parameters for 2027, outlining potential changes to the ACA Marketplace.
If finalized, these updates would affect how plans are designed, how subsidies are managed, and how coverage is displayed on HealthCare.gov and other federal Marketplace platforms.
Here’s what you need to know.
1. Standardized Plans Would Be Eliminated on the Federal Marketplace
CMS proposes ending standardized plan requirements on:
- The Federally Facilitated Exchange (FFE)
- State-Based Exchanges on the Federal Platform (SBE–FPs)
That means:
- Insurers would no longer have to offer standardized plans.
- HealthCare.gov would no longer highlight or separately display them.
- Plan designs could vary more from one insurer to another.
State-Based Exchanges that run their own platforms could still choose to require standardized plans.
Why this matters: Standardized plans were meant to make it easier for consumers to compare options. Without them, plan differences may become less consistent across insurers.
2. Bronze Plans Could Have Higher Out-of-Pocket Limits
CMS proposes allowing some bronze plans to exceed the standard annual out-of-pocket maximum (MOOP), as long as the insurer still offers at least one bronze plan that stays within the normal limit.
What this means: Some bronze plans could expose consumers to higher maximum costs before coverage fully kicks in. However, at least one compliant bronze option would still be available.
3. Catastrophic Plans Would Cover Even Less Upfront
Starting in 2027, CMS proposes that catastrophic plans would not pay for most services until a person reaches 130% of the annual out-of-pocket limit, except for preventive services and limited primary care visits
What this means: People enrolled in catastrophic plans could face higher costs before coverage begins helping with expenses.
4. Marketplace User Fees Would Increase
CMS proposes the following user fees for 2027:
- FFE: 2.5% of monthly premiums
- SBE–FP: 2.0% of monthly premiums
These fees help fund Marketplace operations. Insurers may factor these costs into premium pricing.
5. Faster Penalties for Not Filing Taxes (APTC Reconciliation)
The proposal would move to a one-year Failure to File and Reconcile (FTR) policy, meaning consumers who do not file and reconcile their premium tax credits for one tax year could lose subsidy eligibility sooner than under current policy.
Federal Marketplace Exchanges intend to adopt this policy as early as 2027.
Why this matters: Consumers will need to stay current on tax filing and reconciliation to maintain subsidy eligibility.
6. Changes to Immigration-Based Subsidy Eligibility
Under related federal legislation, only individuals defined as “eligible noncitizens” would qualify for premium tax credits beginning in 2027. Some lawfully present immigrants who previously qualified may no longer be eligible.
The proposal also notes that certain federal payments to states operating Basic Health Programs (BHPs) would end beginning in 2027.
The Big Picture
If finalized, the 2027 rule would:
- Give insurers more flexibility in plan design
- Potentially increase out-of-pocket exposure for some enrollees
- Tighten subsidy enforcement rules
- Change how coverage options appear on the federal Marketplace
This is still a proposed rule. Comments are due March 13, 2026.
For more information, please visit: https://www.federalregister.gov/documents/2026/02/11/2026-02769/patient-protection-and-affordable-care-act-hhs-notice-of-benefit-and-payment-parameters-for-2027
To learn how American Exchange can help navigate these changes, schedule time with our team here.
