Crossing the December 15 deadline for January 1 effective dates usually signals a familiar shift in open enrollment: fewer brand-new shoppers, more follow-ups with undecided clients, and a narrowing pool of last-minute opportunities. This year, however, the period between December 15 and January 15 carries more weight than usual. Not because agents don’t understand the deadline, but because many consumers delayed decisions while watching Washington drag its feet.

Between the government shutdown, partisan gridlock, and unresolved debates over ACA subsidies, a significant number of consumers chose to wait. That delay is exactly why the January 15 enrollment deadline deserves extra attention this year.

The Real Issue: Enhanced Subsidies Are Set to Expire

The biggest factor shaping this enrollment season is the likely expiration of the enhanced premium tax credits at the end of the year. These enhancements were originally created under the American Rescue Plan in 2021 and later extended through 2025. Unless Congress acts, they are scheduled to expire on December 31, 2025, meaning they would no longer apply to coverage beginning January 1. According to the Congressional Research Service, the rules regarding premium tax credit eligibility and calculations would revert back to the original Affordable Care Act framework.

It’s important to be precise here, especially given how the story is being told in the media. The premium tax credit itself is not disappearing completely. What’s expiring is the enhanced version that increased the subsidy amounts most people receive and removed the 400% federal poverty level (FPL) income cap. Under the old (pre-enhancement) rules, financial assistance still exists, but it will be significantly smaller for many households, and for some, it will disappear entirely.

Why Clients Are Confused

A lot of recent coverage reduces this story to headlines suggesting that “ACA subsidies are ending.” That may be a convenient way to tell the story quickly, but it’s misleading. The distinction between the base ACA tax credit and the enhanced credits isn’t intuitive for consumers, and the result is predictable: confusion, hesitation, and delayed enrollment decisions.

Most Consumers Will Pay Significantly More

The Kaiser Family Foundation (KFF) has been clear about the impact if the enhanced credits expire. Their analysis shows that net premiums – what people actually pay after subsidies – would more than double on average for Marketplace enrollees compared to what they would pay if the enhanced credits were extended.

KFF also notes that many middle-income households who currently qualify for assistance only because of the enhanced rules (those earning more than 400% of the FPL) would lose eligibility altogether, while others would face substantially higher required contributions under the original ACA formula.

That backdrop helps explain why some consumers are struggling to commit, and why agent guidance is especially important right now.

Still Time to Sign Up for 2026 Coverage

Most agents don’t need to be reminded that enrolling by January 15 typically results in a February 1 effective date. What’s different this year is why clients are still undecided.

Many delayed enrollment while waiting to see whether Congress would act. Others were spooked by headlines suggesting subsidies were “going away,” without understanding what that actually means. And some are experiencing real sticker shock as they compare current premiums to what they’ve been paying for the last four years.

That creates a narrower but more meaningful opportunity between now and January 15: helping clients make an informed decision instead of opting out due to confusion.

How to Frame the Conversation

At this point in open enrollment, the conversation isn’t about finding the perfect price; it’s about helping clients understand their options and the consequences of going without coverage.

Helpful talking points include:

  • Explaining that some financial assistance remains, even if the enhanced credits expire
  • Clarifying the difference between the original ACA subsidy structure and the temporary enhancements
  • Framing coverage as protection against catastrophic risk, even if monthly premiums increase

For many clients, coverage may be more expensive than they’d like, but it’s still far less costly than going uninsured.

Final Thoughts

This open enrollment season is more complicated than most, not because the rules changed mid-stream, but because policy uncertainty has disrupted consumer confidence. Regardless of whether Congress provides clarity before then, though, January 15 is the last opportunity for most people to enroll in coverage for 2026 unless they later experience a qualifying life event.

Agents who focus on education, explain the subsidy story accurately, and help clients make informed choices will continue to add real value, even in a more challenging selling environment.