Buying health coverage without an employer got harder at the end of 2025, and the reason is legislative rather than commercial. The enhanced premium tax credits enacted in the American Rescue Plan and extended by the Inflation Reduction Act applied to plan years 2021 through 2025 and expired on 31 December 2025. Congress has not enacted an extension. That returns the Marketplace to the original Affordable Care Act subsidy structure, including the hard eligibility cutoff at 400 percent of the federal poverty level.
The practical consequence for anyone shopping now is that the subsidy calculation is the whole game, and a household a few hundred dollars either side of that cutoff faces a very different price. That is worth modelling before choosing a plan, not after.
Start with Medicaid and CHIP, because they are not seasonal
Most coverage advice starts at the Marketplace. The order should be the other way round for anyone with a low or irregular income, because Medicaid and CHIP enrollment is open all year rather than confined to a window, and because eligibility is assessed on current monthly income rather than on a projection for the year ahead.
That distinction matters for self-employed and gig households whose income arrives unevenly. A quarter with little work can qualify somebody for Medicaid even where the annual figure would not. Applying through HealthCare.gov or the state marketplace routes the application to the state Medicaid agency automatically, so a single application tests both.
Eligibility rules vary by state, particularly on whether the state expanded Medicaid, so the state agency is the authority rather than any national summary.
The Marketplace, and the dates you can actually rely on
Open enrollment for the following plan year opens on 1 November. Enrolling by 15 December is what produces coverage starting 1 January, and that is the date to work to.
The closing date is genuinely unsettled as of this writing, and any article stating it flatly is overreaching. A CMS rule finalised in 2025 shortened the federal window to end 15 December; a federal court vacated that provision in June 2026 and the matter may be appealed. Several state-based exchanges run longer windows regardless. The honest instruction is to treat 15 December as the deadline, confirm the current date for your state on HealthCare.gov or the state exchange, and treat anything later as a bonus rather than a plan.
Outside open enrollment, a Special Enrollment Period requires a qualifying life event such as losing other coverage, moving, marriage or a birth, and generally allows about 60 days to act. Losing job-based coverage is a qualifying event, which is the route most people leaving employment will use.
COBRA: a real option priced like a punishment
COBRA continues the exact employer plan already in place, which is its one genuine advantage: the same network, the same doctors, and a deductible already partly met this year. Nothing else replicates that mid-treatment.
The cost is the shock. An employee typically saw only their payroll share; COBRA charges the full premium plus an administrative fee. The number roughly quadruples for many households, not because anything changed but because the employer subsidy stopped.
Two timing points decide whether it is the right call. Losing job-based coverage opens a Marketplace Special Enrollment Period, so COBRA and a subsidised Marketplace plan are a live comparison rather than a sequence. And COBRA premiums do not qualify for premium tax credits, so a household eligible for a substantial credit is usually comparing an unsubsidised full premium against a subsidised one. Somebody mid-course through treatment may still rationally choose COBRA to keep the network and the accumulated deductible.
Anybody at or approaching 65 should read the COBRA decision differently again, because it does not delay Medicare enrollment and does not prevent the Part B penalty. That is covered in our note on enrollment timing at 65.
Where short-term plans are the wrong tool
Short-term, limited-duration insurance advertises hard into exactly this audience, and it is a different product rather than a cheaper version of the same one. It sits outside the individual-market requirements of the ACA, which means medical underwriting is permitted, pre-existing conditions may be excluded, essential health benefits are not required, and dollar caps are allowed.
It is also the wrong comparison in most cases. Short-term plans do not qualify for premium tax credits, so the honest comparison for a subsidy-eligible household is against the net Marketplace premium rather than the sticker price. And the federal duration rules have moved three times in eight years and are currently on the books but not being enforced, so what you can buy depends on your state.
The full picture, including what the current federal rule says and why enforcement was stood down, is in our separate guide to short-term health insurance rules in 2026. The short version for this article: a genuinely short, defined gap with no Marketplace option available is the case it was built for, and an indefinite substitute for comprehensive coverage is not.
The metal tiers describe who pays when, not how good the plan is
Bronze, silver, gold and platinum describe the share of costs the plan expects to cover, not the quality of the network or the care. A bronze plan is not a worse plan. It is a plan that moves more of the cost to the point of use.
One asymmetry is worth knowing because it is easy to miss. Cost-sharing reductions, which lower deductibles and out-of-pocket maximums for households under 250 percent of the federal poverty level, attach only to silver plans. Somebody eligible for them who buys bronze because the premium is lower forfeits a benefit that does not appear in the premium comparison at all.
The comparison that survives contact with reality is premium times twelve, plus the deductible, against the out-of-pocket maximum as the worst case. Run it for a normal year and for a bad one. A plan that wins on the first and loses badly on the second is a bet on staying well.
What to do, in order
- Estimate next year’s household income honestly, including self-employment. The subsidy is calculated on projection and reconciled on the tax return, so a low guess produces a bill later.
- Apply through HealthCare.gov or your state exchange once. That single application tests Medicaid, CHIP and Marketplace subsidies together.
- Check where you sit against 400 percent of the federal poverty level for your household size, because the cliff is back and a small income change either side of it moves the price a long way.
- Compare on total cost, not premium. Premium plus deductible plus the out-of-pocket maximum, against the care you actually expect.
- Get free help rather than paid help. Navigators and certified assisters are funded to enrol people, not paid commission on which plan they choose.
Questions readers actually ask
Did subsidies go away completely?
No. Premium tax credits still exist under the original Affordable Care Act rules. What expired at the end of 2025 were the enhancements from the American Rescue Plan and the Inflation Reduction Act, which had applied to 2021 through 2025. The practical effect is that the eligibility cutoff at 400 percent of the federal poverty level is back, and households above it get no credit at all.
Can I get coverage outside open enrollment?
Through a Special Enrollment Period, which needs a qualifying life event such as losing other coverage, moving, marriage or a birth, and generally gives about 60 days. Medicaid and CHIP are different: enrollment there is open all year, which is why they are worth testing first rather than last.
Is COBRA or a Marketplace plan cheaper?
Usually the Marketplace plan for anyone eligible for a meaningful premium tax credit, because COBRA premiums do not qualify for one and you pay the whole premium plus an administrative fee. COBRA still wins in specific situations: mid-treatment, a deductible already largely met, or a network that no Marketplace plan in the area replicates.
What happens if I estimate my income wrong?
The credit is advanced monthly on your estimate and reconciled on your tax return. Earning less than projected generally produces a refund of the difference. Earning more can mean repaying part or all of the advance, and crossing 400 percent of the poverty level can mean repaying it entirely. Self-employed households should update the marketplace mid-year when income shifts rather than waiting for the reconciliation.
Sources
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Every figure in this article traces to a government record or to a named independent, non-commercial research body. We do not cite insurance marketplaces or affiliate comparison sites for data.
- HealthCare.gov / Centers for Medicare & Medicaid Services Health Insurance Marketplace: open enrollment, special enrollment periods, Medicaid and CHIP, and cost-sharing reductions Published 2026-01-01Supports: Open enrollment for the following plan year opens 1 November, with enrollment by 15 December producing coverage effective 1 January; special enrollment periods require a qualifying life event and generally allow about 60 days; Medicaid and CHIP enrollment is open year round and a single marketplace application tests Medicaid, CHIP and marketplace subsidies; cost-sharing reductions attach only to silver plans; metal tiers describe the share of costs the plan expects to cover.
- U.S. Congress / statute American Rescue Plan Act of 2021 and Inflation Reduction Act of 2022, enhanced premium tax credit provisions Published 2022-08-16Supports: The enhanced premium tax credits applied to plan years 2021 through 2025 and expired 31 December 2025, returning the marketplace to the original ACA subsidy structure including the eligibility cutoff at 400 percent of the federal poverty level.
- Centers for Medicare & Medicaid Services Marketplace Integrity and Affordability final rule, and subsequent litigation Published 2025-06-20Supports: A CMS rule finalised in 2025 shortened the federal open enrollment window; a federal court vacated that provision in June 2026 and the closing date is unsettled pending possible appeal, so 15 December is the only date reliable in every scenario. NOTE: end-date treated as CONTESTED in the article and deliberately not stated as settled fact.
Figures last verified August 30, 2026.