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An overview of the proposed ACA-related changes

Before we dive into it, here's a quick glance at the provisions included in the bill that passed the House. I've also updated to include the provisions from the Senate bill but they're not included in this snapshot list.

  • Revised standards for income verification processes
  • Modified eligibility redetermination procedure
  • Denial of coverage for Deferred Action for Childhood Arrivals (DACA) recipients accomplished by removing them from the definition of “lawfully present” for eligibility and enrollment in Marketplace and Basic Health Program (BHP) coverage
  • New requirement for pre-enrollment verification for Special Enrollment Periods (SEPs)
  • Adoption of the evidentiary standard CMS uses to assess whether to terminate an agent’s, broker’s, or web-broker’s Marketplace Agreements for cause
  • Prohibit issuers from providing coverage of sex-trait modifications as an essential health benefit (EHB)
  • Revise actuarial value standards for health plans
  • Require Marketplaces to deny eligibility for advance payments of the premium tax credit (APTC) upon a tax filer’s failure to reconcile APTC for one year
  • Revise the automatic re-enrollment hierarchy
  • Change the annual Open Enrollment Period (OEP)
  • Eliminate the SEP for persons with annual household incomes below 150% of the federal poverty level (FPL)
  • Revise the premium adjustment percentage methodology
The creators and supporters of this bill insist that these and other policies in the proposed rule are designed to
  • stabilize the risk pool,
  • lower premiums, and
  • reduce improper enrollments with a goal of
    • improving health care affordability
    • improving health care access while
    • maintaining fiscal responsibility.

A quick read of the details makes it obvious to anyone capable of critical thinking that this simply isn't true and the actual goal is to increase barriers to care for certain groups/populations of consumers in the US. This is especially disappointing since one of the original three goals of the ACA is to ELIMINATE BARRIERS TO AFFORDABLE HEALTH CARE.

redglossyiconsizeQUICK FACTS FROM KFF

I have positioned this up front so we get a feel for what’s at stake here before we even start talking about anything else:

"Congressional Republicans are considering a budget reconciliation package that would make significant changes to Medicaid and the Affordable Care Act (ACA). For example, the Energy and Commerce Committee released legislative text that includes work and reporting requirements for certain Medicaid enrollees and codifying changes in a recent Trump Administration proposed rule on the ACA Marketplaces, among other policy changes.

The Congressional Budget Office (CBO) estimates that, taken together, these changes will result in at least 13.7 million more uninsured people in the year 2034 than would otherwise be the case, including:

  • 1.8 million more uninsured from codifying the recent Trump Administration proposed rule on the ACA Marketplaces
  • 7.7 million more uninsured resulting from a combination of Medicaid and other ACA changes (that go beyond the proposed rule)
  • 4.2 million more uninsured with expiration of the enhanced premium tax credits, relative to an estimate of a permanent extension of those credits"

A quote from the Association of State and Territorial Health Officials (ASTHO):

On May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1) by a 215-214 vote. This reconciliation bill proposes changes to Medicaid, the Affordable Care Act, food nutrition programs, and the nation’s debt limit, among other things.

If this bill were signed into law, several potential impacts to states include:

  • Increased coverage loss for noncompliance with work requirements.
  • Future challenges for states to fund their share of Medicaid and SNAP.
  • Limitations on how states incentivize high-quality care or improve access to care as a result of caps on future state-directed payments.
  • Potential increase in food insecurity for vulnerable populations.

    And one more thing to keep in mind going forward…

The Original Three Goals of the ACA

Expand health insurance accessgavelscales

The ACA aimed to ensure that more people had access to affordable health insurance by creating a system (the marketplaces) where individuals AND small businesses could purchase SUBSIDIZED insurance plans.

Expand Medicaid coverage

The ACA expanded Medicaid eligibility to include more low-income individuals, particularly those with incomes up to 138% of the FPL (federal poverty level).

Reduce healthcare costs

The ACA sought to lower healthcare costs through various mechanisms, including supporting innovative healthcare delivery models and promoting competitions between insurers.

As you read these proposed changes, ask yourself how they are going to help achieve any of these goals. (Spoiler alert: THEY WON'T and I feel like many of them aim to do the exact opposite.) Also remember that I've only included the ACA-RELATED PROVISIONS here. There are also major changes proposed for Medicaid, Medicare, and Health Savings Accounts (HSAs) so stay tuned. I'm going to do my best to do a similar summary for those (while also trying to finish publishing my Marketplace comprehensive guide I've been working on since last year. By the time I get it all published, I'll have to go back and rewrite it because of all these changes but hey - doing this helps me learn and I like sharing the knowledge because some of this stuff is so unbelievable I'm just glad to have a witness!)

Okay okay okay. Before my ADHD brain totally derails this train of thought, for better or worse, let's dig into it. I love KFF but when I turned to them for a summary of these provisions, I could not read it the way it was presented so I put it in a format I could understand. I hope it works for you, too. Just in case it doesn't, the link to the source doc from KFF is included below, along with links for further information (as always). 

There are currently some sections with no links at all and this is due to a huge lack of reliable info as things are continuing to change and develop so rapidly. I will add relevant links as I'm able to find them if they're a solid source and I can feel confident in standing behind the facts they're reporting. Also, my patience with typing with arthritis is wearing thin as I get older. I've used abbreviations and acronyms in this quite a bit more than I usually like to because I don't want readers who don't know them to feel left out. If you don't know one of them, just click this text for the CMS Acronyms reference. There are 4,421 acronyms/abbreviations included so I'm confident it will cover whatever you're looking for AND it's searchable! 

 

MEGAPHONEPNKWAIT! WE HAVE AN UPDATE!

UPDATE AS OF JUNE 17, 2025
(via Tracking the Affordable Care Act Provisions in the 2025 Reconciliation Bill | KFF)

First came the Big Ugly Bill (I refuse to say the actual name) and the House passed their Budget Reconciliation Bill on May 22. There's now a Senate-proposed bill with a whole new set of proposals as of June 16. I'm going back and adding those details at literally the last minute. I got up this morning to proof my blog post one last time before publishing it and just became aware of this development a couple of hours ago.

After the new info is added, I'm publishing without looking back so if there are formatting mistakes or something doesn't get linked or anything like that, bear with me. I'm not actually a news reporter. I just apparently play one on the internet.

The Senate bill does not propose changes to all of the same sections as the House Budget Reconciliation Bill so I'm only adding them where they apply. If there's a section that says nothing about the Senate proposal for that issue, it's because they didn't address it.

For ease of formatting and to (hopefully) keep from wrecking my previous work, the Senate bill details have been added under the content boxes for the current law and the House bill. Thank you for your patience. Share some with me, please, because my patience level is getting LOW. Effective dates for the Senate portions are in the content box with them. The effective dates next to the links underneath the content boxes are the proposed dates for the provisions from the House bill. I apologize for the confusion. 

UPDATE AS OF JUNE 24, 2025

Right after I finished adding and formatting the content from the Senate bill, the HubSpot editor glitched and I lost half of my previous work and ALL of the updated content. I decided in a moment of frustration to scrap the whole thing but haven't been able to let it go so I'm redoing it and publishing now, as-is. I hope it helps someone understand what we're up against. As I said before, if there any formatting or linking errors or anything, bear with me. I can barely see straight at this point due to having grown so incredibly tired of this piece and the topic itself. Please contact me and I'll be glad to fix anything I missed.

 

DETAILS OF CURRENT LAW VS ACA–RELATED PROVISIONS FROM BILL

(Source: Tracking the Affordable Care Act Provisions in the 2025 Reconciliation Bill | KFF)

Open Enrollment Period (OEP)


YELLOWPNKRECOLOR150X150EFFECTIVE DATE: Plan years beginning Jan 1, 2026 (OEP beginning Nov 1, 2025)

 

Special Enrollment Periods (SEPs) (E&C)

 

Pink and white megaphone icon

Senate-Proposed Bill

No provision, but see section below about ending financial assistance for people who do enroll via a non-QLE SEP.

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years on or after Jan 1, 2026 

 

Special Enrollment Periods (SEPs) and tax credit eligibility (W&M)

 

Pink and white megaphone icon

Senate-Proposed Bill

Same as the Ways & Means portion of the House bill, but with a different date of effectiveness.

EFFECTIVE DATE: plan years beginning after Dec 31, 2025

Author's note: I can't see how this can be viewed as anything other than a deliberate barrier to low income individuals' access to affordable care, putting it in direct opposition to the original goals of the ACA.

 

Pink and white calendar icon on yellow circle background. Decorative use only.EFFECTIVE DATE: The third full calendar month following the date the bill is enacted 

 

Verifying personal information (E&C)

 

Pink and white megaphone icon

Senate-Proposed Bill

No provision, but see section below about pre-enrollment verification.                                                                                                                                                                                            

Pink and white calendar icon on yellow circle background. Decorative use only.EFFECTIVE DATE: plan years on or after Jan 1, 2026

 

 

Verifying personal information (W&M): Pre-enrollment verification of eligibility for premium tax credit (PTC)

 

Pink and white megaphone icon

Senate-Proposed Bill

Requires pre-enrollment verification of eligibility, but with some notable differences from the House bill:

• Exchanges do not have to additionally verify consumer eligibility for CSRs before a consumer can qualify for PTCs.
• Specifies exchanges must use applicant’s “household income” for verification. House bill only references “income.
• Specifies exchanges must verify whether applicant is an “eligible alien.” House bill requires verification of “any immigration status.”
• Exchanges can use any third-party sources and any available data for verification.
• Verification requirements may be waived for individuals enrolling during SEPs due to changes in family size.

 

EFFECTIVE DATE: Taxable years beginning after Dec 31, 2027             

YELLOWPNKRECOLOR150X150

EFFECTIVE DATE: taxable years beginning after Dec 31, 2027

 

Filing and reconciling

 

Pink and white megaphone icon

Senate-Proposed Bill

No provision, but see section below on repayment of the premium tax credit.                                                                                                                                                                                                                         

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years on or after Jan 1, 2026  

 

Actuarial value (AV)

AUTHOR'S NOTE: I have to admit that I barely understand this one, if I understand it at all. If it doesn't make sense to you, you are not alone! Here's a quick definition to help us understand enough to get through reading it.

 

Actuarial value:

The percentage of total average costs for covered benefits that a plan will cover. 
For example, if a plan has an actuarial value of 70%, on average, you would be responsible for 30% of the costs of all covered benefits. However, you could be responsible for a higher or lower percentage of the total costs of covered services for the year, depending on your actual health care needs and the terms of your insurance policy. Actuarial value - Glossary | HealthCare.gov

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years beginning on or after Jan 1, 2026


Premium adjustment percentage (PAP) methodology


YELLOWPNKRECOLOR150X150

EFFECTIVE DATE: calendar years beginning Jan 1, 2026

 

 

Recapture of excess premium tax credits

  
Pink and white megaphone icon

Senate-Proposed Bill

Same as the House bill with one exception:

Includes a safeguard for individuals who project they will make at least 100% FPL but actually have incomes less than 100% FPL. If individuals did not act “with intentional or reckless disregard for facts” when attesting their income, they will not have to repay their excess tax credits.

EFFECTIVE DATE: taxable years beginning after Dec 31, 2025 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: taxable years beginning after Dec 31, 2025

AUTHOR'S NOTE:  This one is a big deal. ↑ This is what people worry so much about and what I worried about when I got my APTC the first time. My agent reassured me by telling me about the cap on how much or little would need to be paid back or I don't think I could have accepted it the first time because of worry.

 

Premium underpayments and effectuation of coverage

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years beginning on or after Jan 1, 2026

 

Automatic reenrollment

 

Pink and white megaphone icon

Senate-Proposed Bill

No provision similar to the E&C portion of the House bill, but see section above about pre-enrollment verification, which effectively ends auto-renewals altogether.

YELLOWPNKRECOLOR150X150

EFFECTIVE DATE: plan years beginning on or after Jan 1, 2026

 

 

CHOICE arrangements

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: taxable years beginning after Dec 31, 2025

 

 

Employer credit for CHOICE arrangements

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: taxable years beginning after Dec 31, 2025

 

 

Prohibits coverage of gender affirming care as an EHB (essential health benefit)

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: On or after Jan 1, 2027

 

ACA Marketplace coverage eligibility for lawfully present immigrants

 

Pink and white megaphone icon

Senate-Proposed Bill

Same as the Ways & Means portion of the House bill, with one exception:

Does not limit eligibility for cost sharing reductions (CSRs) to specific classes of "eligible aliens".

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: beginning Jan 1, 2026

 

 

ACA Marketplace coverage eligibility for Deferred Action for Childhood Arrivals (DACA) recipients

 

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: Jan 1, 2026

 

 

Cost-sharing reductions (CSRs)

 

Pink and white megaphone icon

Senate-Proposed Bill

Same as the House bill.                                                                                                                                                                                                                                                                       

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years beginning on or after Jan 1, 2026

 

Limitation on use of CSR funds for abortions

 

Pink and white megaphone icon

Senate-Proposed Bill

Same as the House bill.                                                                                                                                                                                                                                                                       

YELLOWPNKRECOLOR150X150EFFECTIVE DATE: plan years beginning on or after Jan 1, 2026

 

THE END… A woman with a frustrated expression on her face and smoke coming out of her ears.of section 1

So that's it for the changes to the ACA. What didn't make sense? Let me know so I can clear it up for you and for everyone else (because if one person is confused by something, you can bet they're not the only one).

Now all that's left are the sections for changes to Medicare, Medicaid, and HSAs (Health Savings Accounts)! Oh boy. I can't wait.

I hate that I can't get these done faster but I'm going out of my way to be as thorough and accurate as possible so I don't post something incorrect and send someone into a panic. My one woman researching, writing, webpage building department is working as fast as it can.

After finishing this, finding out the morning I was going to publish that there was a new Senate bill, adding and formatting all that information while struggling with the HubSpot website builder, and then LOSING ALL OF THAT EXTRA WORK, I decided to quit this piece entirely out of sheer exhaustion of the subject BUT... I can't let things go that easily. I had to redo the last few sections of this altogether and am adding the Senate provisions back in the best I can without driving myself crazy. I just have to get it out of my brain and onto the blog and then I can move on to the next one. Please forgive any errors as I can't even see anymore. Please contact me and let me know of anything that needs fixing and I'll be glad to do it!

 

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