The year-round special enrollment period (SEP) that allowed low-income consumers—those with household incomes up to 150% of the federal poverty level (FPL)—to enroll at any time in Marketplace coverage has been discontinued. This change removes a key avenue for vulnerable Americans to access affordable health coverage outside of standard open enrollment windows.
Background: The Purpose of the Low-Income SEP
In September 2021, the U.S. Department of Health and Human Services (HHS) introduced a SEP enabling year-round ACA-compliant plan enrollment for individuals earning up to 150% of the FPL who qualified for premium tax credits. The initiative was available in all states using HealthCare.gov and optionally offered in state-based exchanges—most of which adopted it.
This SEP was originally tied to the enhanced subsidies of the American Rescue Plan (ARP), which made benchmark silver plans free for low-income enrollees. The SEP was expected to remain as long as the ARP subsidies continued. In April 2024, HHS extended the SEP permanently, even beyond ARP’s 2025 expiration, ensuring access for low-income individuals.
Policy Shifts and the Elimination of the Low-Income SEP
In a sharp reversal, federal rule changes in June 2025 temporarily suspended the low-income SEP from August 25, 2025, through 2026. Then, the “One Big Beautiful Bill Act” (OBBBA), enacted in July 2025, imposed permanent restrictions. Beginning in 2026, Marketplace subsidies are no longer available to individuals enrolling through income-based SEPs that are not linked to qualifying life events. This effectively nullifies the low-income SEP permanently, as unsubsidized coverage remains unaffordable for most at or below 150% of the FPL.
What the SEP Previously Allowed
Under the discontinued SEP, eligible applicants could enroll anytime in ACA-compliant plans, with coverage beginning the first day of the following month. There were no limitations on how often the SEP could be used or which plans could be chosen. Even current enrollees could switch plans, though deductibles and out-of-pocket maximums would reset. These features provided continuous protection for the most economically vulnerable households—an option that is now gone.
Ongoing Eligibility for Subsidies
Individuals who qualified for the low-income SEP may still receive premium and cost-sharing subsidies. However, they must now wait for the annual open enrollment period or experience a qualifying life event to obtain Marketplace coverage. The dedicated income-based SEP no longer provides a year-round safety net.
State-Based Alternatives to the Federal SEP
Although federal rules have eliminated the low-income SEP nationwide, some state-run exchanges offer similar programs. As of August 2025, state exchanges were required to stop offering the federal version, but states continue providing other income-based options through Medicaid and Basic Health Programs (BHPs).
Examples include:
- Oregon and Minnesota — Offer year-round BHP enrollment up to 200% of FPL.
- Washington, D.C. — Plans to implement a BHP in January 2026, covering up to 200% FPL after reducing Medicaid eligibility from 215% to 138% FPL.
- New York — Currently allows enrollment up to 250% FPL, transitioning to a 200% FPL BHP in July 2026.
- Massachusetts — Provides ConnectorCare coverage up to 500% FPL, with ongoing SEP availability for residents under 150% FPL.
- Connecticut — Offers the Covered Connecticut program for adults earning up to 175% FPL.
Options for Those Affected by the Change
Consumers who no longer have access to the low-income SEP must now enroll during the annual open enrollment period to maintain coverage. Even without ARP’s enhanced subsidies, significant premium assistance remains available for those under 150% FPL. Individuals should also remain vigilant for special enrollment opportunities tied to qualifying life events, such as job loss or loss of other coverage, which typically allow 60 days to apply.
Conclusion
The elimination of the ACA’s low-income SEP marks a significant shift in access for financially vulnerable Americans. While other state and federal programs continue to provide some protection, the loss of year-round enrollment poses new barriers. It is now more critical than ever for low-income individuals to plan ahead, understand their state-specific options, and act promptly during open enrollment or qualifying events to maintain essential health coverage.
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