For the first time in Affordable Care Act (ACA) history, the Open Enrollment Period (OEP) on HealthCare.gov is being permanently shortened by a full month. With millions of members historically enrolling in those final weeks, issuers now face a compressed timeline—and a higher risk of membership loss—heading into Plan Year 2026.

In this episode of Regulatory Joe, we break down what this change means for your enrollment strategy and share key actions health plans should take now to retain members, strengthen operations, and prepare for growth.

What’s Changing for ACA Open Enrollment in Plan Year 2026

The new OEP runs from November 1 through December 15, eliminating the usual grace period that extended into January. This is the first permanent shift to the enrollment window outside of a national emergency, and it reshapes the entire curve of member behavior.

Plans that previously relied on late-season enrollments now face real risk. Internal data shows that 3–10% of total ACA membership typically enrolls between December 15 and January 15. Without a proactive strategy, those members—and the revenue they represent—may be lost.

ACA Crosswalk Strategy: What to Reevaluate for a Shortened OEP

Crosswalk decisions may have been submitted in June, but they shouldn’t be treated as final.

With shortened enrollment, evolving market competition, and product changes happening industry-wide, now is the time to revalidate your assumptions. Revisit your 2026 crosswalk and product strategy with a focus on:

• Metallic tier changes: Ensure crosswalks across Gold, Silver, or Bronze tiers comply with actuarial value rules down to the decimal.
• Top-performing plans: Analyze enrollment by HIOS ID to understand which products are driving engagement.
• Portfolio shifts: Reassess any recent additions like PPOs, EPOs, off-exchange, or ICHRA-focused plans. Don’t stop at internal data. Leverage CMS Public Use Files (PUFs) and SERFF filings to understand competitor strategy—especially in light of major shifts like Aetna’s marketplace exit, which could create growth opportunities for regional carriers.

Preparing Your Health Plan Operations for a New ACA Timeline

The shortened OEP leaves no margin for error. Plans waiting on approvals before beginning setup risk missing critical deadlines.

Plans should begin benefits configuration and claims setup immediately, coordinate with IT to ensure systems are synced ahead of enrollment and prepare service teams to answer a wide range of member questions.

This is also the time to assess staffing needs. Adding and training call center reps now can help absorb the spike in member inquiries and support quality onboarding.

How to Communicate Health Plan Changes and New Deadlines

Member communication needs to start earlier this year—and carry more weight. Retention will depend heavily on clear messaging, early outreach, and regulatory-ready marketing assets.

Here’s what your teams should be doing now:

• Develop a coordinated marketing plan with campaigns mapped to the new deadline.
• Submit advertising filings to your state DOI well in advance of open enrollment.
• Train service reps to clearly explain plan changes, tier shifts, and the reasons for auto-enrollment under crosswalk strategies.

With the enrollment window compressed, members have less time to act—and less patience for confusion. Your messaging must be sharp, timely, and accessible.

Regulatory Joe Recommendations for the Shortened ACA Enrollment Period

1. Quantify the risk to your plan’s membership: Analyze prior-year data to identify how many members enrolled after December 15. That late-window cohort could represent a meaningful percentage of your ACA book—and must be accounted for in retention planning.
2. Revalidate your crosswalks: If your product mix or tier structure has changed since the June 11 submission, revisit your crosswalks. Use the latest AV calculator and confirm that crosswalks across tiers meet CMS compliance thresholds.
3. Mine competitor intel for growth: Use CMS PUFs, URRTs, and SERFF filings to evaluate competitor crosswalks and product strategies—especially in markets where Aetna is withdrawing. These are your highest-potential areas for member acquisition.
4. Start configuration now, even if approvals are pending: Begin internal setup for benefits, claims, and enrollment platforms now. Waiting for final approval risks a scramble that can lead to failed onboarding or denied claims during the critical early days of coverage.
5. Submit ad filings early and scale your support team: Proactively file your advertising materials to avoid last-minute delays. At the same time, begin hiring and training call center reps to manage a higher volume of calls during a tighter window—especially from members impacted by crosswalks.

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Episode Transcript

Hey everybody. Welcome to Regulatory Joe. I’m Joe Boyle, president of ClearFile, and on today’s episode we’ll be discussing plan year 2026 enrollment strategies.

Plan year 2026 open enrollment is shaping up to be one of the most condensed and competitive years in the history of the ACA.

Harnessing the changes for plan year 2026, issuers will have to be very aware on not just retaining their existing membership base, but also planning strategically on how to grow their membership through a year of carrier decisions to enter net new markets and also withdraw from existing markets.

So here’s what’s changing for Plan Year 2026. Looking back in time, this is the first time in the history of the ACA that the core annual cyclical enrollment period has ever changed. In all historic years leading up into plan year 2026, members across the country enrolling on exchange on healthcare.gov have always been afforded the opportunity to enroll from November 1st through January 15th. The only exception to the rule in the past 10 years of the ACA that changed the annual cyclical window of enrollment was the COVID pandemic.

AEP now runs one month shorter than it ever has in the history of the ACA. Members will have an opportunity this year to enroll into coverage from November 1st to December 15th.

While the change in enrollment is a very disruptive change to members, issuers have to be very mindful about the impact of what this means in terms of their plan portfolio strategy, and their overall enrollment strategy.

Looking into plan year 2026, we encourage all issuers and payers to take a hard look at their previous historic enrollment trends and understand on a weekly basis how members have historically enrolled into your product, starting November 1st, all the way through January 15th. What you’ll need to absolutely do is understand, in that latter four weeks between December 15th and January 15th, the percentage of your overall ACA membership that actually effectuated during that period of time.

If you’re a smaller, more regional carrier, we estimate that this could make up about three to 5% of your overall total ACA membership.

If you’re a larger carrier, this could make up to over 10% of your overall total membership. Understanding the type of member and understanding their behavior and why they’re enrolling this late into the AEP period is going to be very important as well. Understanding if the member doesn’t have correct access to technology to simply navigate the enrollment or reconciliation process.

Maybe there is a language barrier or a literacy barrier to actually understanding the application for healthcare.gov. Maybe a member simply doesn’t have the time because they’re too busy working multiple part-time jobs and they simply don’t have a navigator or somebody supporting them, like a broker to help them enroll.

So that being said, when you truly understand the percentage of membership that has historically enrolled in that latter four week period of the annual AEP cycle, that’s really going to empower you as an issuer, as a payer, regardless if you’re a regional payer, a smaller payer in one or multiple states to alter and augment your strategy to be proactive and not reactive to do what’s best for your business. So we understand this is a year of disruption, a year of change, and a year of reactiveness in some cases. So being able to get ahead of your plan strategy will be critical and also very timely because we know enrollment’s right around the corner and plans have definitely competing priorities as we’ve just completed the filing season and have entered the review period.

Make sure you’re prioritizing AEP strategy against the change and against the new timeline.

And we can talk all day about what this means on a strategic level from an AEP perspective, but it’ll even be more important to talk about the tactical execution of the crosswalk hierarchy.

And for any filer out there listening, you know well and clear that CMS required all issuer crosswalks to be submitted in alignment with the June 11th deadline of this year. So going into AEP we already know our issuers have made prospective determinations of where they have their current membership today, in calendar year 2025, and where they propose to crosswalk these members on the hierarchy into their net new plans in plan year 2026.

So if you’ve already made your crosswalk determinations in your initial 6/11 submission, those assumptions are probably based on not just the shortening of the AEP period, but those crosswalks and those hierarchies that you submitted has probably been based on other strategic initiatives driven by the change of the ACA.

On a normal year, you’re going to be crosswalking a one-to-one, one-hundred percent renewal. What we’ve seen very quickly this year is we’ve seen issuers scramble where they may have had a one-to-one renewal strategy a month ago, but due to the looming extension, issuers that were historically HMO issuers, we’re actually seeing create new PPO products. Issuers who are historically a PPO issuer, we’re seeing create new EPO products. We’re even seeing issuers driving their products outside the exchange to file off exchange only portfolios, ICHRA portfolios, or even products outside of the ACA entirely.

So all to say the crosswalk hierarchy, CMS will be reviewing these up until 11/1 and issuers need to be a hundred percent sure and confident of where their members are currently and where they’re crosswalking them from the next plan year.

So that being said, we encourage all issuers between now and 11/1 to take a real hard look and a historic look about how your product team or your benefits team have set up the current structure with how you’re planning to map your members into plan year 2026. So taking a look and split it into two or three categories. We would recommend, standard plan options, non-standard plan options, your off exchange business and any non-core ACA products, on your product shelf to truly understand a few criteria.

The number of membership in your plans by HIOS ID and by product id, that’s going to actually tell you what your top performing plan is and quite frankly why members are so attracted to that plan design.

Why is a member needing that coverage? Are there certain benefits that are more desirable than your top competitors’ plans or top comparable plan by your top competitor? Drilling down, not just with membership, but then by metallic tier type. So understanding that issuers this year have not just crosswalk by different products, but the number of plans by metallic tiers has changed.

So we’re actually seeing, in some cases, members who have historically enrolled into gold plans now being crosswalked on the hierarchy to a silver plan. And is that allowed? Understanding your plan AVs are going to be very, very, very critical, down to the decimal or the 0.01% to making sure you’re following your five UBM or uniform benefit modification criteria.

Make sure your plans are within plus or minus 0.2 or 2% of your actuarial value so that if you choose to crosswalk plans across metallic tier, gold to silver, silver to bronze, bronze to silver, silver to gold, that you’re actually doing it in a compliant way. So run that AV calculator, first look to see if there’s a new version of the AV calculator.

Download it on the CMS application page. Run your plans even if it’s already submitted. All plan crosswalks, if you intend to participate on the marketplace, have already been submitted on 6/11. Even though you’re in the review period, go back and still complete this review.

And it’s really important to talk about this right now because as this is a year of disruption and change for the ACA specifically for crosswalk and enrollment, the decision you make for plan year 2026 will carry forward through plan year 2027, 2028, 2029 and so on. The message here is just to be absolutely sure of your crosswalk strategy for this year.

so that you can retain, your existing membership like we talked about, and that you can grow your business and also spend time strategically, obtaining business from your top competitors. While you’re actually looking at your crosswalks, you can pull, even your competitor crosswalks, use the CMS PUF files.

The public use files should be refreshed on a monthly, or at this point, a quarterly basis. You should actually have line of sight into how your top competitors crosswalked their plans last year by membership. Take a couple minutes to look at that, to understand where they’re at, and then also look in SERFF Filing Access.

See what data you can pull from your publicly available URRTs. You can actually track your top competitors’ projected membership for this year. So even if you don’t know their actual membership, even looking at their projections of what they thought they were going to attain to make those types of lines of insights.

So with all the changes that carriers have to accommodate for plan year 2026, it’s going to be important to also pause and acknowledge Aetna’s decision to withdraw from the marketplace for this year as well.

So that decision, while creating opportunity for some regional carriers or other large carriers in the industry also causes a lot of change and disruption for the over million members that are impacted by the decision.

Understanding that these million members are dispersed across multiple different states in a variety of geographies, counties and zip codes. What we would encourage issuers to do, whether you’re another large issuer or a smaller regional issuer, even a hospital health plan, is to understand the markets that you participate in, that also Aetna had competed with you in in that geography. If you understand that if there are plans offered within those same zip codes within those counties, all of that can be extracted through public information requests or downloads through the PUF files or SFA. You’re gonna have a really good understanding of your opportunity for your carrier and for your issuer about how many members were participating in what types of plans and how those plans were built and designed.

And I know it may sound very tactical and detail-oriented. And yes, it will take a lot of time to dive into the details and understand the impact of a Fortune four issuer withdrawing from the marketplace and what that means for your business. But it truly will only help you position your issuer for a better plan strategy beyond plan year 26 into 2027 and into 2028. And while we see carriers making strategic changes or proposals to change, it’s really interesting because while some are continuing to consider different product types or different products entirely, some have also taken the opportunity to explore the differences between having a presence on the exchange as well as off of the exchange.

So if you are considering offering off exchange only portfolios or considering offering mirrored portfolios for the individual or small group markets, also, just be mindful as you go into this shortened enrollment period for the first time ever that, also, SEPs may not be guaranteed for issuers entering plan year 2026.

So what this means is while anything’s possible, we can’t guarantee that members will have an opportunity after December 15th to continue enrollment into the calendar year of 2026. Now, that may not be the case if your strategy is to offer a standalone off-exchange portfolio. Outside of the exchange, SEPs may still be upheld by your respective state and by your enrollment partners.

But again, just to be very clear, on-exchange is not guaranteed for the individual marketplace.

Now that we know and are familiar with all the changes that we’re up against this year, we can talk about how to codify your issuer retention strategy and some other operational strategies to tackle ahead of enrollment.

So from a retention strategy perspective, we really break this into two buckets.

What can we control and what is out of our control? So what we’d recommend is there are controllable filings that wrap around your core, major medical submissions that you can actually submit to a state regulator your marketing, for your product. Advertising filings are allowed post submission, post 6/11 up until 11/1 and ongoing through the next calendar year. So what we’d encourage you to do is to work with your marketing team internally to understand any new advertisements, campaigns, whether they’re posters, commercials, radio advertisements, or other that your marketing team is putting together to build their strategy, to collect as much members as they can and to retain as many members as they can from their current book of business. Working with your marketing and your product team, you should be able to develop process to notify your regulators that advertising filings will be on the way and they should be expecting them.

Speaker: Once any ad filings are submitted by your product filers and approved, those can be used to go to market. And that content can be reused for your next year strategy and the year after that.

Separate from retention strategies, we can talk about some operational items that you can execute to be successful to get ahead of AEP, to make sure you’re on track. Starting with, just because your filing is still under review by your regulator doesn’t mean that you can’t start configuration processes inside of your internal database to make sure you could administer the plans and administer the claims when a member actually enrolls.

There is an ongoing annual argument between product and IT, generally speaking, with payers and issuers across the country, and it goes like this. Why would we configure our products if the filing hasn’t been approved yet? What if something changes? Product will always respond and say, well, we need to because we don’t have enough time. We need to be prepared for 11/1 AEP, regardless if there’s a product change. We are big believers that configuration can never wait. There is never too soon to start coding your benefits into your claims adjudication system because the last thing you want to do is a mad scramble push and missing a sink window where a member will enroll into a plan, receive coverage and receive care, and their claim is not administered and their claim is not paid.

That’s the last situation you’d ever want to be in with a member, especially a new member, that’s joining your plan for the first time. So understanding you’re getting ahead of config. you know, under the notion that making a few changes at the end of the line is, better than the whole and building a business process in place.

So being operationally ready is critical this year more than any year in the ACA because of the substantial change, that’s being pushed on issuers. Amongst the year of AEP shortening, hierarchy of enrollment, don’t let that distract you from other operational execution strategies, as well as retention strategies that you need to get ahead of.

And even right on the heels of configuration and retention, planning for your new members will be crucial. Just because you can now accept them into your claims adjudication system and enrollment platform seamlessly, you need to make sure that your members are welcomed within your sales and service team, and that your internal operations are actually able to ingest an influx of membership. So it’s not uncommon to start hiring classrooms of call center representatives, beginning your training programs and training platforms, making sure that these agents and call reps understand your brand product portfolio, so that they can understand the questions when the member calls in to ask why was I crosswalked, or why was I enrolled into a plan. So making sure that you’re armed with the tools in your toolkit to serve the members, that are paying their premiums. This will only prepare you for a very successful retention strategy year over year.

At the end of the day, it’s really important just to remember to pause, step back and say, not one individual issuer has been siloed with these changes. Everybody across the country who participates in the ACA has been impacted by these regulations and mandated decisions. Executing these changes and being compliant and serving our members with a quality product will take a lot of time, material, and resources.

Set the time aside now for at the end of the year, prior to planning for your plan year 2027 strategy, conduct a lessons learned. Carve out the time, whether it’s a full day session, two half day sessions, virtual or in person with your core staff.

Get members or leaders from your product team, your benefits team, your actuarial pricing team, even down to your claims team and even your product strategists. It’ll be worth the time to document the changes that were executed this year to build your repository. Establish one if you don’t have one, and then build your repository year over year.

Harnessing the impact of what the decisions you’ve made this year and what that means for your membership next year, because the clock starts ticking January 1st. you should be measuring, I mean, if you can on a daily basis, membership activity, but that’s not always feasible, unfortunately.

Track your membership weekly and check in from your lessons learned on a monthly basis throughout your product strategy timeline next year. Generally speaking, and we’ll just give you a rule of thumb, all issuers should have their plan portfolio strategies completed by the end of February annually.

So really you’re thinking you’ve got the second half of December minus holidays and weekends to the middle of February. Really it’s not that much time. And with all the work that we’re executing this year, it will be very easy to deprioritize lessons learned and actually not do the diligence that’s needed for your business and for your members.

Take some time, conduct your lessons learned, and, believe me, when you can measure performance or speed to market, reduced downtime, reduced errors for your members, and have a true retention strategy for next year, it’ll only, drive your market growth, new market entry, or even expansion of your product.

So we covered a lot today.. Best of luck with enrollment season, everybody. Give us a like, give us share and we’ll catch you all next time.