ConnectorCare, Massachusetts’ signature affordability program, is about to face its first real stress test. For the first time in a decade, federal policy changes threaten to strip away subsidies for tens of thousands of members — and carriers will have to decide whether to adapt or retreat. 

By “wrapping” state-funded subsidies around federal ACA Premium Tax Credits (PTCs), the Commonwealth has extended low- or no-premium plans with minimal copays to residents who otherwise would have been priced out of coverage. As of mid-2025, ConnectorCare covers more than 319,000 members — the highest enrollment in the program’s history. But that success depends entirely on the federal framework. 

Who Will Lose ConnectorCare Coverage Under the 2026 ACA Subsidy Changes

On July 4, the federal budget reconciliation bill changed the rules for PTC eligibility. The result:

A definite loss of coverage for ~33,000 members under 100% FPL

This group represents roughly 33,000 ConnectorCare members. They are largely lawful immigrants — including green card holders, certain humanitarian statuses, and other legally present residents — many caught in Medicaid’s “five-year bar” that delays eligibility for full-scope Medicaid. 

They’ve relied on a unique ACA policy exception allowing PTC eligibility even below 100% FPL. ConnectorCare wrapped state subsidies around those PTCs to bring premiums to $0 or near-zero. 

Under the new law, PTC eligibility for anyone under 100% FPL is revoked, regardless of immigration status. Without that federal base subsidy, ConnectorCare has nothing to wrap around. Without subsidies, a benchmark silver plan could cost $400–$500 per month, a significant share of income for households at the federal poverty level.

A potential loss of coverage for ~19,000 members between 400–500% FPL

These 19,000 members joined through the ConnectorCare expansion pilot, made possible by enhanced PTCs (ePTCs) from the American Rescue Plan Act and extended by the Inflation Reduction Act.  

Those enhancements expire at the end of 2025 unless Congress acts. Without them, members above 400% FPL lose federal PTCs — and ConnectorCare eligibility — overnight. For a family of four in this bracket, losing ConnectorCare could mean going from $150/month premiums to $900/month or more. 

While the first group’s loss is certain, the second group’s fate depends entirely on Congress. For carriers, the operational challenge is the same: plan for membership attrition, product changes, and targeted communications in an already compressed enrollment window. 

Why ConnectorCare Changes Signal Risks for Carriers Nationwide

What happens in Massachusetts rarely stays here. I’ve worked with state-based exchanges across the country, and Massachusetts is often the first mover. If your state operates any form of wraparound subsidy program, the ConnectorCare changes could be a preview of your own market’s future if federal supports shift — particularly if upcoming Notice of Benefit and Payment Parameters (NBPP) rules alter how state wrap programs interact with federal ACA requirements. 

Here’s the kicker: even if membership drops by up to 20%, the filing and compliance work doesn’t.

Whether you’re serving one member or a million, you still have to meet the same regulatory requirements, hit the same deadlines, and maintain the same infrastructure. 

Operational Risks for Health Plans and How to Respond to ConnectorCare Changes

The ConnectorCare changes will test carriers’ ability to adapt without undermining their long-term position. The biggest risks — and how to counter them:

1. Product withdrawals can have lasting consequences

Exiting ConnectorCare or the ACA market outright can trigger long-term licensing impacts. In some states, ACA participation is a prerequisite for offering Medicare Advantage or ICHRA-based plans. If scaling back is unavoidable, consider maintaining “ghost” plans — filed and licensed but not actively marketed — to keep your market presence intact.

2. Cutting staff erodes the expertise you’ll need later

ACA compliance work is complex, cross-functional, and takes years to master. Cutting too deep now can leave you unable to pivot when markets rebound. Maintain dedicated ACA filing and compliance resources, either in-house or through a trusted partner.

3. Ripple effects will reach beyond the individual market

Changes to ConnectorCare plan mix, pricing, or formularies can spill over into small-group products, causing confusion for employers. Use detailed membership and enrollment data — by FPL tier, plan type, and payment status — to guide product strategy and prepare proactive communications.

4. Policy shifts demand active advocacy

Federal and state decisions will shape the future of wrap programs like ConnectorCare, but silence leaves the narrative to others. Across the country, there are currently 20 state-based exchanges (SBEs), 3 state-based marketplaces using the federal platform (SBM-FPs), and 28 states relying on the federally facilitated marketplace (FFM).

We’re still seeing states consider — and make — the transition from FFM to SBE or SBM-FP, which means more markets could be in a position to create wraparound subsidy programs like ConnectorCare. That makes it even more important for carriers to share data with their state exchange, participate in public comment periods, and coordinate across product teams to present a clear, informed position. 

Preparing for PY2026 ConnectorCare Eligibility Changes

From November through January, Massachusetts carriers will be in reactive mode — managing enrollment, suppressing plans, adjusting filings, and preparing for mid-cycle changes. It won’t be easy—or fun. But it’s also an opportunity to stress-test your organization’s agility. 

ConnectorCare isn’t going away, but it is changing. For carriers, the question is: will you navigate the disruption strategically, or will you let the moment dictate your future participation in the market? 

If your state isn’t Massachusetts, pay attention anyway. What’s happening here could be coming to your market next.