Major changes are on the horizon for the Affordable Care Act (ACA) marketplace. With new federal proposals emerging from both Congress and the executive branch, licensed agents need to start thinking strategically about how to adapt. Some of these changes could reshape the enrollment calendar, impact subsidy eligibility, and introduce new compliance standards.

As always, those who are prepared will be positioned to retain more clients and grow their market share, especially if they offer a broad portfolio of carriers.

What’s Being Proposed?

Several key proposals from CMS and members of Congress are advancing. Here’s what agents should be watching:

  • A Shorter Open Enrollment Period
    CMS has proposed ending the Open Enrollment Period on December 15 instead of January 15, reverting to the pre-2022 schedule. This shortens the window to enroll clients and places more urgency on early outreach.
    Source: CMS 2025 Notice of Benefit and Payment Parameters Proposed Rule
  • Elimination of the Special Enrollment Period (SEP) for Low-Income Enrollees
    The year-round SEP for individuals up to 150% of the federal poverty level may be eliminated, leaving these clients vulnerable if they miss the regular enrollment window.
    Source: CMS Proposed Rule, 2025 Benefit Year
  • Expiration of Enhanced Subsidies After 2025
    Without congressional action, the expanded subsidies that currently reduce ACA premiums will sunset at the end of 2025, potentially raising costs for millions.
    Source: Kaiser Family Foundation (KFF)
  • Tighter Eligibility Verification
    New rules are expected to enforce stricter income documentation and eligibility checks to prevent improper enrollments.
    Source: CMS Marketplace Program Integrity Fact Sheet
  • Review and Confirm All Re-Enrollments
    Improper re-enrollments, where a client is auto-renewed without confirming their updated income, address, or household status, are drawing increasing scrutiny from CMS. Take time to verify key details with each client, even if they’ve had coverage in the past. This not only ensures compliance but protects clients from subsidy repayment surprises down the road.

Source: CMS Marketplace Program Integrity Fact Sheet

Carrier Landscape Is Shifting: Aetna’s Exit

In addition to federal policy changes, the competitive landscape is evolving. Aetna recently announced its withdrawal from the ACA marketplace in several states, leaving thousands of consumers without an Aetna renewal option for 2025.

This creates both a challenge and an opportunity.
If you’ve previously enrolled clients in Aetna ACA plans, now is the time to reach out. Early engagement will:

  • Ensure clients aren’t surprised during renewal season
  • Provide peace of mind with a seamless transition to another carrier
  • Help you maintain those valuable relationships and avoid losing clients to competitor agents or direct-enroll platforms

What This Means for Agents

These proposed changes and carrier exits signal a more compressed, competitive, and compliance-driven ACA environment. To stay ahead:

  • Start Outreach Earlier Than Ever
    Especially if the OEP ends December 15, agents will need to begin renewal outreach in October. Target your Aetna clients first.
  • Diversify Your Carrier Portfolio
    To capitalize on every opportunity, agents should be appointed with multiple ACA insurers along with supplemental health carriers like Allstate Health to continue serving clients effectively.
  • Educate Clients and Stay Informed
    Clients need to understand what’s changing. Whether it’s losing SEP eligibility or seeing their plan discontinued, you’ll be their first and most trusted source of information.

How AHCP Can Help

AHCP supports agents with access to a wide array of ACA and supplemental health carriers, tools to manage renewals, and real-time updates on state-by-state market shifts.

Final Thought

This year’s ACA selling season won’t look like last year’s and that’s exactly why agents should be planning now. From regulatory proposals to market changes, the only constant in this business is change.

AHCP is here to help you navigate it and succeed.

Need to update your carrier lineup? Visit ahcpsales.com/our-carriers or contact your AHCP team to get started.