How to Compare 2027 ACA Marketplace Plans Before November 1: The Post-Subsidy-Cliff Open Enrollment Checklist

Open enrollment for 2027 coverage starts November 1, 2026 and runs through January 15, 2027. For most households this is going to be the hardest shopping window in a decade. The enhanced premium tax credits that cushioned ACA premiums from 2021 through 2025 expired on December 31, 2025 and are not in place for 2027. Insurers have filed a median proposed rate increase of roughly 14 percent for 2027, and the Families USA national tracker puts the average filed increase at 15.6 percent. That lands on top of the record 25.5 percent average increase in 2026. If you were enrolled before the enhancements ended, the compounded effect across two years is already visible on your statements.

The temptation during a price-shock year is to let auto-reenrollment pick up where last year left off. That is almost always wrong in 2027. The subsidy formula changed, the benchmark plan in your rating area probably changed, and the plan that was cheapest for your household in 2025 or 2026 may now be the most expensive. The checklist that follows is organized around the four decisions that drive the final price you actually pay next year: your projected income, the benchmark plan you are being compared against, the network, and the drug list. Working through it before November 1 is the single biggest savings move most families can make this fall.

The ACA uses modified adjusted gross income (MAGI) — essentially your tax-return AGI with tax-exempt Social Security, tax-exempt interest, and foreign earned income added back — and compares it to the 2026 federal poverty level guidelines (the FPL in effect at the start of the enrollment window). The 2026 single-person FPL in the 48 contiguous states is $15,650, with $5,580 added per additional household member.

Four percent-of-FPL bands to know for 2027

Applicable-figure percentages are indexed each year; the 2027 figures publish with the final HHS marketplace guidance. The band structure is the pre-2021 ACA framework, back in force for 2027.

The 400 percent band is a bright line, not a phase-out. If your 2027 MAGI projects to $62,600 for a single filer or $84,920 for a two-person household, you still receive the full tax credit at that level. One dollar over and you receive nothing. Six-figure premiums have been reported in rate filings for older enrollees in high-cost rating areas; the dollar difference between $62,599 and $62,601 of MAGI can exceed $10,000 of out-of-pocket premium.

How to project income you don't fully know yet

Freelance and gig income is the usual trouble spot. The marketplace does not use a single number — it uses the projection you provide, verified later against your tax return. Over-estimating costs you nothing except a smaller monthly subsidy and a refund at tax time; under-estimating triggers an advance premium tax credit (APTC) repayment on your return. For 2026, repayment limits are back to the pre-ARPA levels; for 2027 the same framework applies.

The Summary of Benefits and Coverage (SBC) is the standardized four-to-eight-page summary every ACA plan has to publish. During a price-shock year, premium differences across metal tiers compress and widen in ways that are not obvious from the marketplace listing page. The only way to compare 2027 plans honestly is to build the full-year total cost of care, not just the monthly premium.

The three-number formula

1. Annual premium after subsidy — the 2027 net monthly premium times 12.
2. Expected out-of-pocket cost at your utilization — copays, coinsurance, and deductible applied to the services you actually used last year. Pull your 2025 EOBs or your plan's annual summary.
3. Risk-weighted catastrophic exposure — the plan's annual in-network out-of-pocket maximum, which caps your downside if a bad year happens. The 2026 federal cap is $10,150 single / $20,300 family; the 2027 figures publish with the final HHS marketplace guidance.

Compare plans using (1) plus (2) as the "typical year" column and (1) plus (3) as the "bad year" column. A silver plan that looked affordable in 2026 because of enhanced subsidies may now be dominated by a bronze plan with an HSA for low-utilizer households, while high-utilizer households may find that the plan with the higher premium and the lower deductible wins on both axes.

Cost-sharing reductions (CSRs) are the discount that attaches to silver plans only, for enrollees between 100% and 250% of FPL. They lower the deductible, the copays, and the out-of-pocket maximum — sometimes dramatically. Under the pre-2021 ACA rules back in force in 2027, CSRs are unchanged in structure, so a CSR-eligible household should almost always stay in silver.

If your 2027 MAGI projects over 250% of FPL, you are not CSR-eligible and silver's main advantage disappears. In that income band, run the bronze or expanded-bronze versus silver math carefully. For households that rarely hit their deductible, an HSA-eligible bronze with a lower premium often beats silver on total cost even without the enhanced subsidy. For households with ongoing specialty-drug use or chronic condition management, silver often still wins because the copay structure is more predictable.

Networks shift at renewal more than premiums do, and marketplace plans in 2027 are consolidating as some issuers exit rating areas and others narrow their networks to control cost. The marketplace listing shows a provider directory link; the directory itself is often months behind reality.

The three-call protocol

1. Pull the 2027 directory from the issuer's own website (not the marketplace), and search for every provider you see regularly — primary care, every specialist, any mental-health provider, any physical therapist, and your pharmacy. Note the plan name verbatim.
2. Call each provider's billing office — not the front desk — and read the plan name back: "Are you in-network for [Issuer] [Product Name] [Metal Tier] effective January 1, 2027?" Billing offices know what they will accept at the time you ask; front-desk staff often confuse product lines.
3. Ask about tiered or narrow-network variants. A plan name on paper can hide a tier-two network in which your provider is covered but at substantially higher cost-sharing. Confirm the tier.

Formulary tier changes are the single most common cause of "my premium looked fine but now my drug costs $300" complaints in February. Insurers reprice tier placement every year, and specialty drugs in particular can move from tier 3 to tier 4 or tier 5 at renewal. Prior authorization and step therapy requirements can also be added at renewal without changing the formulary status itself.

What to look up for each regular prescription

• Formulary tier for 2027 (not 2026). Tier 1 is generic preferred, tier 2 is generic non-preferred or brand preferred, tier 3 is brand non-preferred, tier 4 is specialty, tier 5 is highest-cost specialty. Different plans use slightly different tier structures — look at the plan's own documentation.
• Prior authorization required or not. If PA is new for 2027, your pharmacy will reject the fill until your prescriber submits the form.
• Step therapy required or not. If step therapy is new, you may need to document that you have already failed the preferred alternative.
• Quantity limits. 30-day versus 90-day fill allowances can shift at renewal.
• Mail-order mandate. Some maintenance drugs can only be filled through the plan's mail-order pharmacy after a certain number of retail fills.

If a drug you depend on moves to a higher tier or adds a utilization restriction, you have options: shop a different 2027 plan that keeps the drug on a lower tier, request a formulary exception, apply for the manufacturer's patient assistance program, or combine a lower-premium plan with a direct manufacturer or 340B pharmacy source. The time to figure that out is in October, not after your January refill is rejected.

HealthCare.gov and most state exchanges will auto-reenroll you if you do nothing. The auto-renewal algorithm picks your current plan if it is still being offered, or a similar plan from the same issuer if it is not. The algorithm then applies whatever subsidy it computes from the income you reported on your 2026 application.

Three things go wrong with auto-renewal in a 2027 price-shock year.

1. The subsidy formula changed. The benchmark plan in your rating area almost certainly moved. Your "advance" subsidy may be dramatically different from what it was last year, and if your income verification is stale the marketplace may apply the wrong number altogether.
2. Your plan's cheapest-silver status moved. The benchmark used to compute your tax credit is the second-cheapest silver plan in your rating area — which usually changes identity at renewal. The plan that was benchmark in 2026 may not be benchmark in 2027.
3. The algorithm does not re-verify your 2027 income. If your income rose or fell in 2026, auto-renewal will apply the old projection and you will get a surprise APTC reconciliation at tax time.

Logging in once between November 1 and December 15 and actively re-selecting a plan takes about 20 minutes and prevents the three failures above. Even if you end up re-selecting the same plan, the act of updating your income projection and the plan selection resets the subsidy for 2027 correctly.

The households hit hardest by 2027 are those just above the 400 percent FPL line and older enrollees whose age-rated premiums have climbed fastest. If you project MAGI just over the threshold and no amount of MAGI engineering closes the gap, four options are worth running the numbers on.

Option 1: Drop a metal tier (or two)

Switch from silver or gold to bronze or expanded bronze. The premium drops meaningfully, but the deductible climbs and some services (like non-preventive office visits) are often subject to the deductible before any copay applies. Pair the plan with an HSA if the plan is HSA-eligible; the triple-tax-advantaged HSA offsets some of the higher cost-sharing.

Option 2: Catastrophic coverage (if eligible)

Catastrophic plans are available to enrollees under 30 and to those who qualify for an affordability or hardship exemption. Premiums are the lowest on the marketplace, but the deductible equals the ACA out-of-pocket maximum — you pay 100% until you hit the ceiling. Three primary-care visits are covered before the deductible.

Option 3: Direct primary care plus a cheaper high-deductible plan

Direct primary care (DPC) subscriptions typically run $75-$125 per month and cover unlimited office visits, basic lab work at wholesale pricing, and generic prescriptions at pass-through cost. Pair DPC with a bronze or catastrophic plan for emergencies and specialist access. For households that rarely need specialist care, this combination often outperforms unsubsidized silver on total 2027 cost.

Option 4: COBRA, employer coverage, or ICHRA if available

If you lost employer coverage recently, run the 2027 unsubsidized marketplace premium against the full COBRA premium. In some high-cost rating areas and family configurations, COBRA (which was previously almost always worse than subsidized marketplace) is now actually cheaper. If your spouse or household member has access to employer coverage, that plan may now be the better option even if historically you preferred the marketplace. If an employer is offering an ICHRA (individual coverage health reimbursement arrangement), the pre-tax dollars can bring unsubsidized marketplace premium down significantly.

State-based exchanges in California, New York, New Jersey, Washington DC, Massachusetts, and several other states have longer windows. Check your state exchange for the specific deadlines.

2027 is the first ACA open enrollment without the enhanced premium tax credits, and the compounded effect of 2026's record 25.5 percent average increase plus 2027's median 14 percent filed increase will show up on net premiums for anyone whose subsidy fell or ended. Six moves before November 1 fix most of it: lock down your 2027 projected MAGI with the 400% FPL cliff in mind, re-pull the SBC and rebuild total-cost-of-care math across typical and bad-year columns, check whether CSR-silver still beats bronze-plus-HSA for your household, verify every provider and every prescription against the 2027 network and formulary, and actively re-select — even if the end answer is the same plan — rather than letting auto-renewal apply a stale subsidy. If the cliff catches you, drop a metal tier, use a catastrophic plan if eligible, combine direct primary care with a cheaper high-deductible plan, or compare COBRA and employer options that used to be worse. The spreadsheet work is tedious. The reward is that your January premium is the number you planned for, not the number that shows up in your email on December 20.