Starting in 2026, the health insurance system through the Marketplace is undergoing more significant changes than seen in recent years. For many families, this will mean new rules for subsidy access, changes in tax calculations, and increased personal costs. To avoid unpleasant surprises, it is worth understanding the details in advance.
Until the end of 2025, a temporary rule was in effect: even families with an income below 100% of the Federal Poverty Level (FPL) could receive assistance if Medicaid was unavailable to them. From 2026, this leniency ends.
Now:
Subsidies are provided only with an income between 100% and 400% FPL.
Below 100% FPL, only Medicaid remains.
If Medicaid is unavailable, insurance will have to be paid in full.
For many immigrants, this is a key change: if in 2025 the Marketplace helped close the “gap” between Medicaid and minimum income, in 2026 this support will disappear.
In 2025, limits existed: even if income turned out higher than stated, you didn’t have to return the entire overpayment. In 2026, these limits are abolished.
Any overpayment is subject to repayment in full. This means income reporting must be as accurate as possible.
If changes occur during the year, it is important to update information in your Marketplace account.
Essentially, the responsibility now shifts entirely to the applicant. Errors in income forecasting can lead to owing thousands of dollars when filing taxes.
Treatment costs continue to rise. In 2026, the maximum limit on personal expenses will be:
$10,150 per person.
$20,300 per family.
This is the upper cap, but the conditions of most plans depend on it. The higher the limit, the greater the financial burden in the event of serious medical expenses.
These plans are officially recognized as HDHP (High Deductible Health Plans). Now they can be used in conjunction with Health Savings Accounts (HSA).
This innovation provides the opportunity to:
Save funds for medical expenses with tax benefits.
Use the HSA as an element of long-term savings.
However, it must be considered that HDHPs imply higher deductibles, so for families with frequent doctor visits, such plans may be financially burdensome.
CSRs remain unchanged:
Available only with Silver plans.
Work with income from 100% to 250% FPL.
Lower deductibles and co-pays, making the plan closer in protection level to Gold.
Benefits for Native Americans and ANCSA Members
Special rules remain: Native Americans and ANCSA members can change or enroll in a plan once a month, without waiting for special periods.
The rule remains the same: if a person is eligible for Medicare, they cannot receive subsidies in the Marketplace.
Open Enrollment for 2026: From November 1, 2025, to January 15, 2026. However, in individual states operating their own Marketplaces, deadlines may differ and be shorter. For example, in some states, registration ends as early as December 31. Therefore, it is important to check dates specifically for your state.
Outside these dates, you can get insurance only if you have a Special Enrollment Period, for example:
Marriage, birth, or adoption of a child.
Loss of other insurance.
Moving to a new area.
Release from incarceration.
Denial of Medicaid or CHIP.
Errors by the Marketplace or insurance company.
What This Means for Families
In 2026, the Marketplace remains a crucial tool for accessing insurance. But the rules are tightening:
Subsidies will become less accessible for low-income people.
Repayment of overpayments is now full.
Treatment costs will rise.
To avoid mistakes, one needs to be more careful with income forecasting and compare plan conditions taking new limits into account.
A licensed broker or agent helps not only to select a suitable plan but also to correctly calculate income, account for tax risks, and avoid overpayments. Additionally, the broker takes on the processing and filling out of the entire application, which saves time and reduces the risk of errors. Broker services are free for the client: they are paid for by insurance companies and do not affect the price of coverage in any way.
If you already have a broker, contact them before Open Enrollment begins to discuss changes. And if you don’t have a broker yet or doubt their competence, you can consult with an expert. Licensed broker Andrii Kuzma is available by phone at (312) 646-0646 and can answer any of your questions regarding insurance, help fill out the application correctly, and select a plan taking the new rules into account.
Disclaimer: This material is for informational purposes and is based on official CMS publications. It does not constitute legal, tax, or financial advice. For full information, please refer to the official website: www.healthcare.gov.
