2027 ACA Benchmark Premiums Are Final in 40+ States: What a Median 18% Hike and the Returning 400% FPL Cliff Mean for Your November 1 Open Enrollment

Six days before the November 1, 2026 opening of ACA Open Enrollment for the 2027 plan year, three facts are now settled.

First, 2027 benchmark Silver premiums are final in more than 40 states — state regulators have signed off on the rate filings insurers submitted in July, and the figures you will see on HealthCare.gov next Sunday are no longer projections. The approved median increase in the benchmark Silver plan is roughly 18%, with eight states clearing more than 25% and only three states landing under 10%.

Second, Congress has not extended the enhanced premium tax credits. The temporary pandemic-era rules that lifted the 400% federal poverty level subsidy cliff and capped net premiums at 8.5% of income regardless of earnings expired December 31, 2025. The Senate failed to pass an extension before the September 30, 2026 shutdown deadline, and while the House is weighing a three-year extension, no vote has been scheduled with six days remaining before OEP opens.

Third, the marketplace preview windows went live October 15. If you have a HealthCare.gov account, you can see your approved 2027 benchmark, your projected 2027 subsidy, and your draft January 1 premium today — without logging into HealthCare.gov blind on November 1 and being surprised by what you see.

This piece lays out what the final 2027 benchmark data actually shows, how the returning 400% FPL cliff reshapes net cost at every income bracket, and the five moves to make between now and November 1. If an extension is passed after OEP opens, the subsidy figures will update retroactively and you will have through January 15 to re-select — so the planning here is written to be useful either way.

Insurers filed proposed 2027 rates with state Departments of Insurance by July 15, 2026. State regulators reviewed, negotiated, and in several cases forced reductions. Final approvals have rolled out through August, September, and October. As of October 23, 2026, 42 states plus D.C. have published final 2027 benchmark data; the remaining jurisdictions are expected to post by October 29.

The headline figure — a roughly 18% median benchmark increase — masks wide dispersion. Three groups:

Three drivers show up repeatedly in the actuarial memoranda regulators published:

• Medical and prescription drug cost trend. Insurers assumed a 10% underlying trend for 2027, up from the 8% that defined the recent decade. GLP-1 agonists (Wegovy, Zepbound) and continued expansion of specialty drug spend account for most of that acceleration.
• Enhanced-subsidy sunset. With net premiums rising for subsidized enrollees who stay enrolled, healthier enrollees are more likely to drop coverage. The sicker risk pool that results pushes rates further up — a measurable 4% to 6% premium effect attributed to adverse selection in most memoranda.
• Operational uncertainty. The year's regulatory environment (CMS Marketplace Integrity Rule changes, state rate-review intensity, pending reconciliation legislation that could cut Medicaid eligibility and push additional enrollees onto the exchange) added a 1% to 3% margin loading in several states.

Rate-review intensity mattered in several states. California, Colorado, Oregon, and Washington required issuers to resubmit lower rates after initial filings. The three low-hike states on the chart above all have aggressive state-level consumer protections, including rate-review authority with teeth and state-level reinsurance programs.

Benchmark premium is only half the equation. Your net cost is benchmark minus subsidy, and for the 2027 plan year the subsidy formula reverts to the pre-2021 schedule for the first time since the American Rescue Plan took effect. Two features of that schedule are back:

1. The 400% FPL cliff. Above 400% of the federal poverty level, the subsidy drops to zero. There is no sliding scale above that income line.
2. Higher expected-contribution percentages below 400% FPL. The pre-2021 schedule asks enrollees to contribute between about 2.07% of income at 100% FPL and 9.83% at 400% FPL. The enhanced schedule in force 2021–2025 ran from 0% to 8.5%, so even subsidized enrollees are being asked to pay a higher share of income for 2027 than they were for 2026.

Three worked examples (all using the national-median approved 2027 benchmark Silver of roughly $655/month for a 40-year-old, which varies by rating area):

Example 1: Single filer, 250% FPL ($39,125 projected 2027 MAGI)

Pre-2021 schedule applicable percentage at 250% FPL: 8.33%. Expected contribution: $272/month. Benchmark Silver: $655. Subsidy: $383/month. Net Silver premium: $272/month. Comparable 2026 enrollee under the enhanced regime at 250% FPL paid about $163/month (4% of income). Change: roughly $109/month higher net Silver premium.

Example 2: Family of four, 395% FPL ($126,900 projected 2027 MAGI)

Pre-2021 schedule applicable percentage at 400% FPL: 9.83%. Expected contribution: $1,040/month. Family benchmark Silver: $2,205. Subsidy: $1,165/month. Net family Silver premium: $1,040/month. 2026 enrollee at the same real income under the enhanced regime capped at 8.5%: about $899/month. Change: roughly $141/month higher net family Silver premium.

Example 3: Same family of four, 405% FPL ($130,100 projected 2027 MAGI)

Above the cliff. Subsidy: $0. Net family Silver premium: $2,205/month. 2026 enrollee at the same income under the enhanced regime: about $923/month (still capped at 8.5%). Change: roughly $1,282/month higher net family Silver premium — about $15,000/year.

The legislative state of play, as of October 26:

• Senate: Failed to pass a clean extension in the pre-shutdown round in September. The post-shutdown continuing resolution funds the government through December 11, 2026 but does not include an enhanced-PTC extension.
• House: Rules Committee is weighing a three-year extension of enhanced subsidies that would restore the 8.5% cap and eliminate the 400% cliff retroactively for plan year 2027. No floor vote has been scheduled.
• Administration: No formal position on an extension. White House statements have focused on broader ACA reform and have not endorsed a clean extension.
• CMS: Operating under the assumption that the enhanced subsidies are expired. HealthCare.gov will display pre-2021-schedule subsidy figures when OEP opens November 1, 2026. If a law changes mid-OEP, CMS has indicated the system can update retroactively.

What this means for you, practically:

• Plan as if the enhanced subsidies are gone, because that is the system state on November 1.
• If a law passes mid-OEP, your subsidy will rise automatically and you will have the balance of Open Enrollment (through January 15 on HealthCare.gov) to re-select without penalty.
• If no law passes, nothing changes about the plan you selected under the pre-2021 schedule — your 2027 subsidy and net premium hold at the figures you locked in.

Either way, the right move is to re-shop deliberately for 2027 rather than relying on auto-reenrollment, which treats your 2026 inputs as still valid and applies them against a materially different 2027 landscape. The auto-reenrollment guide covers the three traps in that default; this piece is about what to do about them.

Mistake 1: Projecting the enhanced schedule

The most common misconception entering 2027 OEP is that the 8.5% cap still applies. It does not for plan year 2027 as of the date OEP opens. If a congressional extension passes, the cap returns; until then, project your net cost against the pre-2021 schedule, which runs higher at every bracket below 400% FPL and vanishes above it. If you set your household budget on the enhanced-schedule assumption and then shop under the pre-2021 regime, you will overshop your coverage and find yourself unable to afford a plan you selected.

Mistake 2: Assuming auto-reenrollment preserves your 2026 subsidy

It does not. Auto-reenrollment carries forward your 2026 income on file and your 2026 household composition and applies the 2027 subsidy schedule to produce a new figure. If your income on file is a 2024 or 2025 figure (the application pulls your most recent tax-filing data), it may understate current earnings and understate the subsidy phase-out, which the marketplace will reconcile at tax time. People who do not log in and update projected income between now and December 15 are most at risk.

Mistake 3: Letting a Silver-plan reshuffle move the benchmark out from under you

The benchmark is the second-lowest-cost Silver plan in your rating area, which changes identity year to year. The subsidy follows the benchmark; your plan does not. If you are enrolled in a plan that was benchmark in 2026 and is no longer benchmark in 2027, your subsidy stays pegged to the new benchmark but your plan's premium follows its own 2027 approved rate — and the two can move in opposite directions. On the November 1 shopping session, re-sort by net cost under the new benchmark; the plan that fits best in 2026 may not be the best fit in 2027 even if its network and formulary are unchanged. The 2027 plan comparison guide walks through the full re-sort workflow.

CMS has indicated that if Congress enacts an enhanced-PTC extension between November 1, 2026 and January 15, 2027, HealthCare.gov will update subsidy figures retroactively to the start of OEP and send push notifications to enrollees whose plan selection is affected. State-based exchanges will follow their own timelines, usually with a lag of one to three weeks.

Practically, for an enrollee who followed the five moves above:

• If you selected a plan in early November under the pre-2021 schedule and an extension passes in mid-November, your subsidy rises, your net cost falls, and your plan selection is unchanged.
• If the subsidy increase makes a different plan more attractive (a Gold plan might become competitive with Silver when net cost is capped at 8.5%), you can re-select without penalty through January 15.
• If you are above 400% FPL under the pre-2021 schedule and an extension restores the cap, your subsidy goes from zero to meaningful, and re-shopping is strongly advisable.

In short: lock in a decent plan for January 1, then re-shop if the legislative environment moves. The downside of over-caution (waiting for Congress and missing December 15) is much worse than the downside of selecting on November 1 and re-selecting if a law changes.

• How to Handle ACA Auto-Reenrollment for 2027 →
• How to Prevent an Unwanted 2027 ACA Auto-Reenrollment →
• How to Compare 2027 ACA Marketplace Plans →
• 2027 ACA Open Enrollment Checklist →
• How to Estimate Income for an ACA Subsidy →
• Year-End MAGI Reduction to Keep the Subsidy →
• How to Avoid Paying Back an ACA Subsidy →
• The ACA Subsidy Cliff Explained →