What ACA changes does the Big Beautiful Bill make, and when do they take effect?

The One Big Beautiful Bill Act (H.R. 1, Public Law 119-21, signed July 4, 2025) phases in Marketplace changes over three years. In 2026: no premium tax credit for anyone who enrolls through an income-based special enrollment period; no subsidy for lawfully present immigrants under 100% of poverty who were barred from Medicaid by their status; no cap on repaying excess advance subsidies starting with 2026 taxes; and bronze and catastrophic plans become HSA-eligible. In 2027: subsidy eligibility for non-citizens narrows to green-card holders, certain Cuban and Haitian entrants, and COFA migrants; Medicaid expansion adults face work or community-engagement requirements, and anyone denied Medicaid for failing them is also barred from Marketplace subsidies. In plan year 2028: subsidized enrollees must verify eligibility before coverage starts, effectively ending passive auto-renewal. Separately — and not part of the bill — the enhanced subsidies expired December 31, 2025. As of October 2026, open enrollment for 2027 runs November 1, 2026 to January 15, 2027. For help choosing or enrolling in a plan, call United Enrollment Services, a licensed insurance agency, at 1-866-401-4116.

What it means

2026 — Income-based SEP enrollees get no subsidy; repayment caps removed for tax year 2026; bronze and catastrophic plans count as HSA-eligible; lawfully present immigrants under 100% FPL lose subsidy eligibility.
2027 — Most lawfully present immigrants other than green-card holders, certain Cuban and Haitian entrants, and COFA migrants lose subsidy eligibility; HHS estimates about 1.23 million people affected. Medicaid work requirements begin (states may get extra time), and failing them blocks Marketplace subsidies.
2028 — Pre-enrollment verification required before advance subsidies are paid; no passive auto-renewal with a subsidy.
Not in the bill — Enhanced premium tax credits expired December 31, 2025. The House passed a three-year extension January 8, 2026; the Senate has not acted.
Not in the bill — A 2025 CMS rule would have ended open enrollment December 15; a court vacated it in June 2026 and CMS confirmed the January 15, 2027 deadline.

Action steps

Use this open enrollment (November 1, 2026 to January 15, 2027) to re-check your eligibility under the 2027 rules.
Plan ahead for the 2026 tax return, which has no repayment cap.
If you are a non-citizen, confirm your immigration category for 2027.
Keep income and identity documents organized for 2028 verification.
Call a licensed agent if more than one of these changes applies to your household.

Risks & deadlines

December 15, 2026: enroll by this date for January 1, 2027 coverage.
January 1, 2027: immigrant subsidy eligibility narrows; Medicaid work requirements begin in most expansion states.
Spring 2027: first tax season with no repayment cap.
Fall 2027: first enrollment season with pre-enrollment verification for 2028 subsidies.

Also asked as

Big Beautiful Bill ACA timeline
When do the OBBBA health insurance changes start?
What changes for Obamacare in 2027?
One Big Beautiful Bill Act marketplace effective dates

Sources

Last verified: 2026-10-27