As the dust settles from the latest ACA filing season, compliance leaders should be keeping an eye on potential policy changes that could alter the ACA landscape.
The recently-passed One Big Beautiful Bill Act (OBBBA) — which builds on a rule initially issued by the Trump administration — includes sweeping changes to Medicaid and the ACA Marketplaces.
These changes reduce insurance coverage for millions, but also increase the compliance burden for employers, health plan sponsors, and ACA filers.
In this blog, we break down what’s included in the bill, how it impacts ACA coverage and compliance, and why now is the time to strengthen your ACA compliance infrastructure.
Millions Could Lose Coverage — Including ACA Expansion Enrollees
According to the Congressional Budget Office (CBO), the Medicaid provisions alone in the OBBBA would increase the number of uninsured individuals by 7.8 million by 2034. This would primarily be driven by:
- Work and reporting requirements for Medicaid expansion enrollees
- Mandatory biannual eligibility redeterminations
- New cost-sharing requirements for low-income participants
- Lower federal incentives for states to expand Medicaid
- Stricter documentation and verification rules that delay or reduce coverage
The result: more individuals dropping off Medicaid rolls, more uninsured Americans, and potentially more individuals seeking employer-sponsored coverage.
Changes to ACA Marketplaces Could Shrink Access Further
In addition to the Medicaid rollback, OBBBA also codifies and expands Marketplace changes that will further reduce coverage access:
- Open Enrollment will be shortened to end on Dec. 15 instead of Jan. 15
- Special Enrollment Periods (SEPs) are restricted, especially for low-income individuals
- Auto-enrolled individuals will face a new $5 charge if they don’t actively verify their eligibility
- DACA recipients will be excluded from ACA Marketplace coverage and tax credits
- Enhanced documentation is required for premium tax credit eligibility
Taken together, these provisions are expected to result in an additional 1.8 million uninsured individuals, according to the CBO.
Expiration of Enhanced Tax Credits Could Undermine ACA Enrollment Gains
The OBBBA does not extend the enhanced ACA tax credits introduced during the pandemic, which are set to expire at the end of 2025. If they lapse, the CBO projects another 4.2 million people will lose coverage by 2034.
These enhanced credits:
- Lowered premium costs by an average of $705/year
- Expanded eligibility to those earning more than 400% of the federal poverty level
- Fueled record Marketplace growth — especially in Republican-leaning states
If allowed to expire, out-of-pocket premium payments could rise by over 75% on average, creating affordability challenges for lower-income, older, and rural populations.
Why It Matters for ACA Compliance
If passed, these changes would have serious implications for ACA compliance, especially for large employers and plan sponsors:
- Greater enrollment volatility: As Medicaid coverage drops and Marketplace subsidies shrink, more individuals may look to employer-sponsored plans, which can complicate eligibility tracking.
- Higher risk of ESRP penalties: Misclassifying or failing to offer affordable coverage to newly eligible employees could lead to increased 4980H(a) and (b) penalties.
- New documentation burdens: Stricter IRS verification standards and eligibility checks may impact how data is collected, validated, and filed.
- Affordability recalculations: The rollback of enhanced tax credits means employers must revisit affordability thresholds and Safe Harbor strategies to avoid underestimating premium burdens.
How Trusaic Helps You Prepare for What’s Next
The legislation shakes up the ACA framework — one with more uninsured individuals and higher compliance risk for employers. Trusaic’s ACA compliance solutions is built to help you manage this complexity with:
- Penalty Risk Assessment: Identify issues in your coverage offers and filing data before they lead to costly penalties.
- Real-Time Eligibility Tracking: Monitor fluctuating employee eligibility driven by Medicaid or Marketplace shifts.
- Safe Harbor Optimization: Calculate and validate affordable coverage contributions with confidence.
- Audit-Ready Reporting: Maintain complete records in case of an IRS inquiry—especially important if enforcement ramps up in a less-subsidized ACA environment.
For employers, the key takeaway is this: compliance is about to get harder, not easier. As coverage gaps widen and verification rules tighten, proactive, data-driven ACA compliance will be more essential than ever.