The Federal Budget Reconciliation Bill Affects Eligibility & Enrollment In ACA Health Insurance Marketplace Plans

The federal budget reconciliation bill, House Resolution (HR) 1, which was signed into law on July 4, 2025, includes provisions that affect Affordable Care Act (ACA) health Insurance Marketplace plans, according to an analysis by KFF, a non-profit organization focused on health policy. Pre-enrollment verification processes, documentation requirements, a shorter open enrollment period ending on December 15, changes to eligibility for immigrants, limits on premium tax credits, and full repayment of excess premium tax credits are among the key changes, the analysis stated.

Changes include:

  • Two plan types—Bronze and Catastrophic—will qualify as high-deductible health plans as required by eligibility for Health Savings Accounts enrollment, according to the analysis.
  • ACA Marketplace eligibility will be limited to lawfully permanent residents and migrants starting January 1, 2026.
  • Any consumer who enrolls in a plan via a non-qualified life event Special Enrollment Period will be ineligible to receive premium tax credits or cost-sharing reductions.
  • Denial or disenrollment from Medicaid due to failure to meet work requirements will remove eligibility for subsidized Marketplace coverage, starting January 1, 2027, or earlier if the state desires.
  • Enrollment in plans with a $0 premium (after tax credits) that is automatically reenrolled in Marketplace coverage will be subject to eligibility verification for a fully subsidized plan with a $5 monthly charge (reduction in tax credits) until eligibility is confirmed.

The full text of Health Provisions in the 2025 Federal Budget Reconciliation Bill was published on July 8, 2025, by KFF. A free copy is available (accessed July 17, 2025).

For more information, contact: Craig Palosky, Director of Communications, KFF, 1330 G Street Northwest, Washington, District of Columbia 20005; Email: cpalosky@kff.org; Website: https://www.kff.org/

November 2025     00US25EUA0044

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