A major shift in ACA Open Enrollment is on the table, and if it moves forward, health plans—especially smaller insurers—will need to rethink their entire approach to outreach, operations and regulatory filings. 

Last week, the federal government proposed shortening the ACA Open Enrollment period, potentially eliminating plan selections between December 15 and January 15. 

While this may seem like a small adjustment, the ripple effects could be significant, affecting enrollment trends, compliance strategies and operational readiness. Health plans need to start preparing now to mitigate potential disruptions. 

How a Shorter ACA Open Enrollment Period Will Affect Smaller Insurers 

Large insurers report that less than 10% of enrollments occur between December 15 and January 15, which might seem like a small percentage. However, for smaller, regional insurers, every enrollment counts. 

Through conversations with industry partners, we’ve seen that 7% of total enrollments for some smaller insurers happen after December 15—a figure that can directly impact financial sustainability. 

Many of these late enrollees come from lower-income populations or have limited access to technology, transportation, and broker support. These members often rely on navigators, last-minute outreach from insurers (calls, texts, emails) and extended decision-making time to complete their enrollment. 

Without this additional window, health plans could see: 

• More coverage gaps, leading to higher uninsured rates and uncompensated care costs for providers 
• Enrollment declines, particularly among populations who depend on assistance to sign up 
• Increased operational strain, as plans will have a shorter timeframe to manage applications and eligibility processing 

For smaller, regional carriers that work aggressively to secure late enrollments, this proposed change represents a fundamental shift that demands a new approach to driving early enrollment and preventing mid-year coverage gaps. 

Why This ACA Change Puts New Pressure on Health Plan Operations and Compliance 

Beyond enrollment trends, shortening the ACA Open Enrollment period presents serious operational challenges—especially for regulatory, enrollment, and billing teams managing compliance and system updates. 

Plans will need to: 

• Develop a proactive communication strategy to prevent enrollment drop-offs and misunderstandings about deadlines. 
• Update internal systems and billing operations to align with earlier payment deadlines and eligibility processing. 
• Coordinate with state regulators and industry partners to align advocacy efforts and compliance strategies. 

For regulatory and compliance teams, filing deadlines and operational readiness will become even more critical. Without proper planning, insurers could face system overloads, increased member confusion and an influx of complains due to unintentional lapses in coverage. 

How Health Plans Can Advocate for ACA Policy Adjustments 

With the comment period closing on April 11, health plans have a limited window to voice concerns and propose adjustments that could lessen the negative impacts of these changes. As of this article being published on March 20, over 120 questions have been formally published, which CMS will be required to respond to by April 11. 

When submitting feedback, plans should highlight the following key concerns: 

• Disproportionate impact on lower-income and rural populations: Many rely on enrollment assistance, and a shorter window could leave them without coverage. 
• Higher risk of gaps in coverage and uncompensated care: Fewer enrollment opportunities could increase uninsured rates, placing a financial strain on providers and state Medicaid programs. 
• Confusion around billing and payment deadlines: Auto-payment failures and misinformation could lead to unintended disenrollments—impacting both consumers and insurer retention rates. 

With smaller and regional health plans feeling the brunt of these changes, it’s critical that insurers take this opportunity to speak up before these regulations become final. 

What Health Plans Should Expect if the New ACA Open Enrollment Rule Moves Forward 

While nothing is set in stone, there’s a strong likelihood this proposal will move forward. The current administration has emphasized reducing federal spending and modifying ACA provisions, making it likely that regulators will push to implement changes for the 2026 plan year. 

Even if adjustments are made after the April 11 comment deadline, regulatory teams should treat this as an inevitable shift and begin planning now. To avoid being caught off guard, regulatory teams should begin evaluating enrollment strategies, system updates, and compliance workflows today. 

Steps Health Plans Can Take Now to Prepare for the New ACA Open Enrollment Rule 

To ensure a smooth transition, health plans should take these immediate steps: 

• Subscribe to ACA rulemaking updates via CMS’s Federal Register to track developments in real-time. 
• Coordinate internal teams (compliance, enrollment, product, etc.) to craft a shared strategy for handling earlier enrollment deadlines. 
• Draft and submit your comments before the April 11 deadline, focusing on the specific impact to your plan’s market and operations. 
• Adjust internal workflows to ensure system readiness for earlier enrollment deadlines, payment cycles and testing processes. 
• Work with compliance and regulatory experts like ClearFile to build a long-term strategy for navigating this change efficiently. 

The Bottom Line 

Regulatory changes like these don’t wait for health plans to adjust. If this proposal moves forward, insurers will need to adapt quickly, refining enrollment strategies, tightening compliance workflows, and ensuring systems are ready for an earlier cutoff. 

The best approach? Be proactive. Get involved in the rulemaking process, refine outreach strategies, and prepare systems now. Health plans that get ahead of these changes will navigate the transition smoothly—and those that don’t may find themselves scrambling to catch up.