New Marketplace Rules for 2025

From Beyond the Basics

The Centers for Medicare & Medicaid Services recently issued its annual update to private market rules for 2025, which contains a number of changes to ACA marketplace operations. See a summary here and highlights below.

• Low-income SEP: The rule extends the SEP for people with incomes at or below 150 percent FPL indefinitely. Previously, this SEP was set to expire on December 31, 2025. This SEP is currently available in the FFM and at State Based Marketplace (SBM) option.
• Length of open enrollment: For coverage beginning January 1, 2025 or later, all states, including those with SBMs, must have an open enrollment period that begins on November 1 and ends no earlier than January 15. States that currently have open enrollment periods that begin before November 1 may continue to do so, as long as their open enrollment period lasts at least 11 weeks.
• SEP coverage effective dates: As of January 1, 2025, in all states including SBMs, marketplace coverage must begin on the first day of the month after plan selection for SEPs with regular coverage effective dates. See our SEP Reference Chart for coverage dates and additional information about SEPs.
• Non-standardized plan limits and exceptions: Beginning in plan year 2025, insurance companies that offer plans on the ACA marketplace can offer no more than two non-standardized plans for each product network type, metal level, and service area. Previously, issuers could offer no more than four standardized plans. However, there will be exceptions to this limit for non-standardized plans that have “specific design features that will substantially benefit consumers with chronic and high-cost conditions.” To understand more about standardized (or “Easy Pricing”) plans, see our guide.