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The One Big Beautiful Bill Act is a separate law from the subsidy expiration you may have already heard about — and it changes how you enroll and stay enrolled, not just what you pay. Here’s what actually shifts for 2027 marketplace coverage.
Published August 7, 2026 · By Erik Roti, Options.Health
It’s easy to lump every recent ACA headline into one story, but there are actually two separate things happening. The enhanced subsidy amounts expired on their own timeline at the end of 2025 — we covered that in an earlier post. The One Big Beautiful Bill Act (OBBBA), signed into law in July 2025, is a different piece of legislation entirely, and most of its marketplace provisions don’t take effect until 2027. This post is about that second piece: what OBBBA itself changes, separate from the subsidy amounts.
For years, if you did nothing during open enrollment, your marketplace plan would typically auto-renew. OBBBA introduces new pre-enrollment income and eligibility verification requirements for anyone receiving premium tax credits — which effectively ends automatic re-enrollment as it has worked in the past. Starting with 2027 coverage, expect to need to actively re-verify your information each year rather than assume your plan carries over unchanged.
A federal rule originally set out to shorten the Annual Open Enrollment Period nationwide to November 1 through December 15. That rule has since been vacated by a federal court, and the deadline situation is genuinely still in flux state by state. For Minnesota specifically, MNsure has confirmed the 2027 open enrollment period will run November 1, 2026 through January 15, 2027 — enroll by December 15, 2026 for coverage starting January 1, 2027, or enroll between December 16 and January 15 for a February 1, 2027 start date. That's actually a return to a longer window than MNsure had briefly announced earlier in the year, after the original federal rule was struck down. Given how much this has already shifted, it's worth double-checking MNsure's site directly as the date approaches rather than relying on any single snapshot — including this one.
If your income during the year ends up higher than what you estimated when you enrolled, you can owe back some of the premium tax credit you received. Previously, the amount you had to repay was capped based on your income level. OBBBA removes that repayment cap, meaning if your actual income comes in well above your estimate, you could owe back the full excess subsidy rather than a limited amount. This raises the stakes on estimating your income carefully when you enroll, particularly for anyone with variable or seasonal income.
For anyone who auto-re-enrolls in a fully subsidized ($0 premium) plan without actively re-verifying their eligibility, the new rules reduce the advance premium tax credit applied by $5 per month. It’s a modest number on its own, but it’s one more reason actively logging in and confirming your information each year beats letting a plan roll over untouched.
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