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Important ACA Marketplace Changes Starting on or before January 1, 2026


by CHRISTY DIEHL & WHITNEY KLINGELE S


everal updates to the Affordable Care Act (ACA) will change due to the 2025 Marketplace Integrity and Af- fordability Final Rule or the recently


passed One Big Beautiful Bill Act. The rule adds safeguards to protect consumers and establishes standards to ensure the integrity of the exchanges. These changes may affect your individual health insurance coverage and financial assistance; and, more updates are still coming. Please review the updates carefully to avoid any disruptions in your coverage and stay aware of forthcoming rule revisions. Following is a summary of what’s changing.


HSA ELIGIBILITY EXPANDED TO BRONZE & CATASTROPHIC PLANS


Starting in 2026, consumers with high- deductible bronze and catastrophic market- place plans will be eligible to contribute into a health savings account (HSA). In addition, consumers with HSA qualified health plans will be allowed to have direct primary care (DPC) membership while making HSA con- tributions, if the DPC meets certain require- ments. The DPC membership fee will be considered a qualified medical expense and can be paid with pre-tax HSA funds.


ENHANCED PREMIUM TAX CREDITS EXPIRING


These are currently set to expire at the end of 2025 unless Congress acts. Premium tax credits will be reduced, which could result in an increase of 2026 monthly premiums. The advanced premium tax credits as part of the Affordable Care Act remain in place.


HIGHER OUT-OF-POCKET LIMITS


Maximum out-of-pocket costs for ACA plans will increase in 2026 to more than $10,000 in some plans.


VERIFICATION EXTENSION ROLLED BACK


Beginning August 25, 2025, the automatic 60-day extension has been removed for consumers to resolve data matching issues. Consumers can request a 60-day extension if they demonstrate good faith effort has been made to obtain the required documenta- tion during the 90-day period. This period shrinks from 150 days to 90 days.


DACA RECIPIENTS LOSE ELIGIBILITY


Beginning August 25, 2025, individuals with Deferred Action for Childhood Arrivals (DACA) status will no longer qualify for ACA coverage, cost sharing reduction or premium tax credits and are excluded from the defini- tion of “lawfully present” for purposes of enrollment.


Of important note, in late August, a federal district court in Maryland issued a temporary nationwide stay order blocking key parts of the Trump administration’s new marketplace rule that were scheduled for implementation on August 25. Depending on further actions in court, these items could be reactivated. Stay alert of further rule revisions that we’ll share as we become aware of them.


Christy and Whitney are your health insurance team at MDIS. To learn more about changes to the ACA Marketplace plans, or to inquire about group and individual health plans, call 573-636- 8752, email info@mdis4dds.com or visit mdis4dds.com.


FTC Announced: Won’t pursue ban on noncompete agreements


T


he Federal Trade Commission announced it will not fight a lower court’s decision to throw out a nationwide rule that would have banned noncompete agreements.


The FTC voted 3-1 on September 5 to dismiss its appeals in two court cases and accept a ruling by a federal court in Texas that ruled the federal agency exceeded its statutory authority when it approved the ban and that the noncom- pete rule is “arbitrary and capricious.” If enacted, the noncompete ban would have impacted an estimated 30 million workers.


“Despite this ruling, employers and employees should also continue to consider applicable state laws, as many states have already enacted legisla- tion restricting these agreements,” said Michael Kim, J.D., ADA associate general counsel. “This does not elimi- nate the possibility that the FTC could seek to enact a more narrow rule in the future.”


While the nationwide rule will not move forward, the FTC has indicated it will review and, where appropriate, challenge noncompete provisions on a case-by-case basis under its existing enforcement authority. On September 4, the day before voting to dismiss its appeals, the FTC filed a complaint against Gateway Services, a pet crema- tion company, for allegedly using overly broad noncompete agreements.


“This action shows us that while the FTC won’t be pursuing a complete ban on noncompete agreements, it hasn’t lost its focus on the topic,” Mr. Kim said.


See ADA News story at bit.ly/46fzk6S. 24 focus | FALL 2025 | ISSUE 3


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