1. What was supposed to change for 2027
In June 2025 the federal government finalized a regulation called the Marketplace Integrity and Affordability Final Rule. It was a substantial package, and several parts of it were written to take effect with the 2027 plan year — the coverage you would be signing up for this coming November.1
Four of its provisions mattered most to ordinary households:
| What the rule said | Who it would have affected |
|---|---|
| A shorter open enrollment window. On the federal Marketplace, enrollment would run November 1 to December 15 rather than to January 15, starting with plan year 2027. | Everyone. It removed a month from the window, and the month it removed is the one people actually use. |
| Losing your subsidy after one missed reconciliation. If you took an advance premium tax credit and did not file a return reconciling it, the Marketplace could cut off the credit after a single year rather than two consecutive years. | Anyone who fell behind on a tax return — which, in practice, is often the households least able to absorb a premium increase. |
| A $5 monthly premium for automatic re-enrollees. People auto-renewed into a zero-premium plan would be charged $5 a month until they confirmed their eligibility. | Low-income enrollees whose subsidy covers the full premium. |
| Tighter special enrollment periods. Including the removal of the monthly enrollment opportunity for people at or below 150% of the federal poverty level. | People whose income changes mid-year, which is most people paid hourly. |
Every article written about 2027 enrollment between June 2025 and this summer described that world. Most of them have not been updated since.
2. What the courts actually did
On June 12, 2026, the U.S. District Court for the District of Maryland, in City of Columbus v. Kennedy, issued an order striking several provisions of that rule — among them the failure-to-reconcile policy. On July 16, 2026, the same court stayed provisions of the separate 2027 Payment Notice, including its own version of the same policy.2
The government appealed the same day. The case is now before the Fourth Circuit and remains pending, which is worth saying plainly: this is unsettled law, and it is reasonable to check the dates again before November.2
An appeal does not change today’s rules
While an appeal is pending, the court’s orders stand. That is why the government issued fresh guidance in July telling Exchanges what to do now, rather than waiting for the appeal to resolve. If the Fourth Circuit rules differently later, expect new guidance then — and expect it to be reported badly, so confirm it at the source.
What matters for you is not the litigation. It is the instruction the government issued afterwards.
3. The dates that apply in Florida right now
On July 27, 2026, the Centers for Medicare & Medicaid Services published an updated statement on how Exchanges must operate for plan years 2026 and 2027. On the enrollment window it is unambiguous:
“HHS … has not altered the dates for the Open Enrollment period … Open Enrollment at the Federally-facilitated Marketplace will begin on November 1, 2026 and end on January 15, 2027.”
— Centers for Medicare & Medicaid Services, Updated Statement regarding the Failure to File and Reconcile requirement for Plan Years 2026–2027, July 27, 2026.
Florida has no state-run exchange; residents enroll through HealthCare.gov, which is the federally-facilitated Marketplace. So that sentence is the one that governs every household in Broward, Miami-Dade and Palm Beach. HealthCare.gov’s own dates-and-deadlines page lists the same three dates.3
| Date | What it is | What happens if you miss it |
|---|---|---|
| November 1, 2026 | Open enrollment opens. You can enroll, renew or switch plans. | Nothing yet — but plans and prices are visible from this day, and the earlier you look, the more room you have. |
| December 15, 2026 | Last day to enroll or change plans for coverage that begins January 1, 2027. | You can still enroll, but your coverage will generally not start until February 1 — leaving you a month uninsured. |
| January 15, 2027 | Open enrollment closes. | You generally cannot buy Marketplace coverage for the rest of the year unless you have a qualifying life event. |
Do not treat January 15 as your plan
The extra month is real, but using it costs you January. Someone who enrolls on January 10 has coverage starting February 1 and pays out of pocket for anything that happens in between — and January is when deductibles reset and prescriptions get refilled. Treat December 15 as your deadline and January 15 as your safety net.
Free, no obligation
Bring us your renewal notice and we will read it with you before November.
4. The change that did survive
One change was not touched by any of this, because it is not a regulation at all — it is in the tax code. The One Big Beautiful Bill Act removed the caps on repaying excess advance premium tax credits, for tax years beginning after December 31, 2025.4
Here is what that means in practice. Your subsidy is calculated in advance from an estimate of your income. If you earn more than you estimated, you were previously protected by a repayment cap tied to your income — often a few hundred dollars. That cap is gone. Now:
- If your income comes in higher than you told the Marketplace, you repay the entire difference at tax time, with no ceiling.
- A raise, a second job, overtime, a good year of self-employment or a spouse returning to work can all trigger it.
- The bill arrives in spring 2028 for 2027 coverage — long after you have spent the money.
- Reporting an income change during the year is not a penalty. It adjusts your subsidy forward so the reconciliation is small.
This is why an accurate income estimate is now the single most valuable thing you can get right, and why letting a plan roll over on last year’s numbers has become a genuinely expensive habit.
5. Why auto-renewal is the expensive default
If you do nothing before January 15, the Marketplace will generally re-enroll you in your current plan, or something close to it if yours is discontinued. That sounds convenient. It is also how most people end up on the wrong plan.
Three things change underneath you every year, and auto-renewal notices none of them:
- Your plan changes. Premiums, deductibles, provider networks and drug formularies are reset every year. The plan that was right last November may not cover your doctor or your prescription in January.
- Your subsidy is recalculated from whatever income information the Marketplace already holds. If your income has moved and you have not told them, the credit applied to your January premium is built on a stale number — and, with the repayment caps gone, that is now your liability.
- The market around you changes. A plan that was mid-priced last year can become the most expensive in its tier without changing a thing, simply because competitors filed lower rates.
6. Why this lands hard in South Florida
Florida has more people on Marketplace coverage than any other state — roughly 4.54M in plan year 2026. Nowhere is that concentration heavier than South Florida, and nowhere are the households more exposed to the repayment change: a large share of Marketplace enrollees here are self-employed or work variable hours, which is exactly the income profile that makes an annual estimate hard to get right.5
It also means the misinformation costs more here than almost anywhere. If a meaningful number of South Florida households believe their window shuts on December 15 and stop looking, some of them will find out in February that they were entitled to a month they never used. That is the practical reason this article exists.
7. What to do in September
Open enrollment is still weeks away, which makes September the useful month — everything below is easier now than it will be in November.
- Estimate your 2027 income honestly, including overtime, side work and a spouse’s income. If it is uncertain, estimate slightly high rather than slightly low; a smaller subsidy now beats an uncapped repayment later.
- Find last year’s Form 1095-A and check that you filed Form 8962 reconciling your credit. The Marketplace cannot cut off your subsidy over it right now, but the law still requires the filing.
- List your prescriptions and your doctors by name. Formularies and networks are the two things that change most often and are checked least.
- Watch for your renewal notice, which arrives in the autumn and shows what your current plan will cost in 2027. Do not recycle it.
- Put December 15 in your calendar, not January 15.
- Report income changes as they happen during 2027 rather than saving them for tax time.
8. Free help, and what to be careful about
Nobody should be paying out of pocket for help with a Marketplace plan. Licensed brokers are compensated by the insurer, and Marketplace navigators and certified application counsellors are free by law. HealthCare.gov’s “Find Local Help” directory lists both, and the Marketplace call centre is open around the clock during enrollment at 1-800-318-2596.6
- Ask whether the person helping you is licensed in Florida, and for their licence number.
- Ask which carriers they can actually offer. No broker represents every insurer.
- Never give bank or card details before you have chosen a plan and seen its premium in writing.
- Be wary of anyone quoting a 2027 premium as certain before final rates are approved and published.
If someone tells you the window closes December 15, ask them where they read it
It is an honest mistake — the rule really did say that, and a great deal of published material still reflects it. But a broker who has not tracked the litigation may also be working from stale subsidy rules, and those affect what you pay. The government’s July 2026 statement and the HealthCare.gov deadlines page are both public; anyone advising you should be able to point to one of them.
9. Frequently asked questions
When does ACA open enrollment actually end for 2027 coverage in Florida?
January 15, 2027. Florida uses the federally-facilitated Marketplace at HealthCare.gov, and a CMS statement issued July 27, 2026 confirms that open enrollment there “will begin on November 1, 2026 and end on January 15, 2027.” A 2025 rule would have moved that ending to December 15, but a federal court struck the relevant provisions in June 2026 and CMS stated it has not altered the open enrollment dates.
Then why do so many websites say December 15?
Because they are describing the 2025 Marketplace Integrity and Affordability Final Rule, which did shorten the window to November 1 through December 15 beginning with plan year 2027. That rule was published in June 2025. What most of those pages have not caught up with is that a federal court struck several of its provisions on June 12, 2026, and CMS confirmed in July 2026 that the enrollment dates are unchanged.
Does December 15 still matter at all?
Yes, and this is the part worth getting right. December 15, 2026 is the last day to enroll or change plans for coverage that starts January 1, 2027. If you enroll between December 16 and January 15, your coverage generally starts February 1 instead. So December 15 is a real deadline — it is just not the end of open enrollment.
I did not file a tax return reconciling my subsidy. Will I lose my premium tax credit?
Not on that basis, for plan year 2026 or 2027. The court struck the failure-to-reconcile policy, and CMS has instructed Exchanges to stop removing or denying advance premium tax credits for having failed to file and reconcile. That said, the law still requires you to file a federal return and reconcile the credit — this only means the Marketplace cannot cut off your subsidy for it right now. File anyway.
Could these dates change again before open enrollment?
They could. HHS filed a notice of appeal on July 16, 2026, and the case is pending before the Fourth Circuit. Nothing about an appeal changes the rules while it is pending, but this is genuinely unsettled law, so confirm the dates at HealthCare.gov before you rely on them — or ask us and we will check with you.
What happens if I just let my plan renew automatically?
You will usually keep coverage, but not necessarily the coverage you would have chosen. Your plan may have changed its premium, network or drug list for 2027, and your subsidy is recalculated from income data the Marketplace has on file, which may be out of date. Auto-renewal is a safety net, not a decision.
Is it true there is no longer a cap on repaying subsidy I was not entitled to?
Yes, and this one is not affected by the court case because it is in the tax law rather than a regulation. The One Big Beautiful Bill Act removed the caps on repaying excess advance premium tax credits for tax years beginning after December 31, 2025. If your income comes in higher than you estimated, you repay the full difference at tax time.
Do I have to pay to get help with this?
No. Licensed brokers like us are paid by the insurance company, not by you, and Marketplace navigators and certified application counsellors are free by law. If someone asks you for a fee to enroll you in a Marketplace plan, or asks for your bank details before you have chosen a plan, stop and get a second opinion.
10. Sources
- Centers for Medicare & Medicaid Services — 2025 Marketplace Integrity and Affordability Final Rule (90 FR 27074), finalized June 2025. As written, it shortened open enrollment on the federally-facilitated Marketplace to November 1 – December 15 beginning with plan year 2027, narrowed the failure-to-reconcile policy to a single year, introduced a $5 monthly premium for certain automatic re-enrollees, and restricted special enrollment periods.
- City of Columbus v. Kennedy, No. 1:25-cv-2114 (D. Md.), order of June 12, 2026, striking provisions of the 2025 Marketplace Integrity and Affordability Final Rule including the failure-to-reconcile policy at 45 C.F.R. § 155.305(f)(4); and No. 1:26-cv-2215 (D. Md.), order of July 16, 2026, staying provisions of the Notice of Benefit and Payment Parameters for 2027 (91 FR 29256). HHS filed a notice of appeal on July 16, 2026; the case is pending before the U.S. Court of Appeals for the Fourth Circuit.
- Centers for Medicare & Medicaid Services — Updated Statement regarding the Failure to File and Reconcile requirement for Plan Years 2026–2027, July 27, 2026: Exchanges must stop removing or denying advance premium tax credits for failure to file and reconcile, and “Open Enrollment at the Federally-facilitated Marketplace will begin on November 1, 2026 and end on January 15, 2027.” Corroborated by the HealthCare.gov dates-and-deadlines page, which lists November 1, December 15 for January 1 coverage, and January 15.
- One Big Beautiful Bill Act, § 71305 — eliminates the caps on repayment of excess advance premium tax credits for tax years beginning after December 31, 2025. See also Internal Revenue Service premium tax credit guidance updated after enactment.
- Plan year 2026 marketplace enrollment: Florida the largest state at about 4.54 million. Reported from CMS enrollment data.
- HealthCare.gov — open enrollment, special enrollment periods and qualifying life events; “Find Local Help” directory of navigators and certified application counsellors. Marketplace call centre 1-800-318-2596 (TTY 1-855-889-4325).
Disclaimer: JCKC Financial Services is a licensed independent insurance brokerage and tax preparation firm. This article is for general educational purposes only and is not tax, legal, medical, or financial advice, nor a substitute for guidance from a licensed professional about your specific situation. We are not connected with or endorsed by the United States government, HealthCare.gov, or the Health Insurance Marketplace. The litigation described here is ongoing and enrollment dates, subsidy rules and poverty-level thresholds can change. Confirm current details at HealthCare.gov, by calling 1-800-318-2596 (TTY 1-855-889-4325), or with a licensed professional before making any decision about your coverage or your taxes.