In today’s episode of Regulatory Joe, we’re tackling new changes to Healthcare.gov in 2025 that will impact both how health plans operate and how members enroll in coverage. 

What is Healthcare.gov? 

Healthcare.gov is the central platform for qualifying Americans to shop for an enroll in ACA-qualified health plans. It serves as the primary marketplace for individuals and families to compare different insurance options, determine eligibility for subsidies and secure coverage for both federally facilitated marketplace plans and state-based marketplace plans. 

What’s changing on Healthcare.gov for 2025? 

As we’ve seen across many updates for 2025, accessibility and user-friendliness are major priorities for CMS. The changes coming to Healthcare.gov in next year focus in on improving user experience and ensuring consistency across state-based marketplaces (SBMs) and the federally facilitated marketplace (FFM). 

Website Consistency 

Whether members are shopping on healthcare.gov or a state-based exchange, the new CMS updates make sure they will experience the same streamlined and user-friendly process. This includes pathways for direct enrollment (DE) and enhanced direct enrollment (EDE), which allow members to enroll in plans directly through insurers or brokers while still using the healthcare.gov infrastructure. Issuers will need to pay close attention to these changes and align their landing pages and enrollment flows with CMS standards. 

Simplified Plan Selection 

In previous years, members were faced with hundreds of plan options while shopping on healthcare.gov. While more plans to choose from may seem beneficial, this abundance of choices often led to confusion, with many selecting plans that didn’t fit their needs. 

CMS is simplifying plan selection by reducing standard options in 2025. Members will now be presented with a more manageable list of plans when they log in and complete their eligibility applications, helping them make more informed decisions and improving plan selection and satisfaction. 

Regulatory Joe Recommendations 

• Test all your plans thoroughly. 
  While it’s tempting to simply spot-check plans, it’s crucial to test every plan in your portfolio and verify that all benefits (ex. PCP copays, specialist copays, additional programs) are displayed correctly. You should also verify rates by county or zip code so all plan data aligns with member expectations. 

• Sync data across all platforms. 
  Beyond healthcare.gov, ensure that your plan data is accurate across all non-marketplace websites, including your own company’s landing pages and any partner sites. Misaligned data can confuse members and lead to incorrect plan selections. 

• Avoid last minute changes. 
  To ensure a smooth certification process, limit last-minute data change requests (DCRs) to those that are strictly necessary for compliance. Last-minute changes can cause significant delays and further jeopardize compliance. 

• Develop a repeatable project plan. 
  This is a process you should be repeating annually, and this is a great time to create a project plan to streamline your process each year. This should include timelines for plan testing, certification and data validation. 

It is critical for issuers and health plans to stay on top of testing, compliance and operational processes to ensure smooth plan selections and enrollment. While operationally challenging, these changes represent a positive shift toward a simplified, more member-friendly experience. 

Be sure to watch the full episode for a more detailed run-down of changes and recommendations. 

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Video Transcript

Welcome to Regulatory Joe. I’m Joe Boyle, the President of Regulatory Solutions here at Penstock. And in today’s episode, we’ll be talking about healthcare.gov and annual changes that will impact you.

So what is healthcare.gov? Healthcare.gov, if you don’t know by now, is the primary shopping and enrollment space for members enrolling into any qualified health plan or ACA plan in the country.

One of the primary changes CMS is enforcing for plan year 2025 is ensuring website consistency across state-based marketplace platforms, as well as the federally-facilitated marketplace.

By enhancing the user experience and simplifying plan selection, it’ll be very important for state-based marketplaces to align with direct enrollment and enhanced direct enrollment policies and procedures that have been administered by CMS on the FFM.

The primary reason that CMS is enforcing this policy change for plan year 2025 is to ensure both consistency for members enrolling within a healthcare.gov web page, as well as a state-based marketplace web page, and to increase the user experience for that member to effectuation of coverage.

We encourage all issuers and all carriers across the country, if you haven’t already, to register for the REGTAP webinar sessions that outline the EDE and DE requirements for state-based marketplaces.

It’s going to be very important to understand these rules and regulations to, number one, see what CMS has changed on their website and administer the changes accordingly to your landing pages yourself, see what’s changing with the enrollment and eligibility application and making necessary changes with your enrollment and billing partners for the SBM, and also ensuring and testing your user experience so that your plans are displaying accurately, timely, and compliantly with the benefits that you intend to offer for plan year 2025 per CMS testing standards.

A lot has changed this year with how CMS has updated the MPMS process, with how plans are tested and displayed, as well as how state-based marketplaces test and produce their shopping environments for members.

Ensuring that these websites align and are synchronous will be critical to the delivery of your 11/1 enrollment and 1/1 effective date coverage.

Similarly, there was an emphasis this year on simplifying plan selection. So in addition to aligning the web pages to CMS standards, regardless of the type of exchange you participate in, understanding that members for the first year ever will have fewer plans to choose from.

When CMS released the latest NBPP for plan year 2025, there was a heavy emphasis on simplifying plan selection. Now, when we talk about updating the user experience of a member shopping on healthcare.gov or any state-based exchange shopping environment, it’s really important to understand what a member sees.

Prior to this year, members would be posed with hundreds of plans to choose from.

By reducing the number of standard plan options put forth by CMS, members will now see a simplified list of plans to choose from on the federal marketplace.

So when logging in and completing their eligibility application, that will be one of the first things that they see on the web page on healthcare.gov.

Now, while the filtering options still may be the same where you can filter by price, by brand, by company, by payer, members will have more of a simplified user experience, and also working with navigators to pick the plan that meets their healthcare needs the most.

Prior to this year, there have been too many times where members are pushed into plans or picking plans that are not the right fit for their health plan needs, or where they’re either paying too much for services that are underutilized or not utilized at all.

While making website updates can be seemingly frustrating at times, we do see that this is overall favorable to the member and will streamline policies and procedures internal to a health plan, as well as supporting quick enrollment and reporting on the federal exchange.

So when we talk about recommendations on how to make this process smooth for your organization, there’s a couple things to consider.

At this point in the year, filings are being approved and disposed. You’re likely starting the RBIS process, underway for submission and validation. All of that data that you’re working on currently prior to open enrollment on November 1st is going to be critical to plan test, to plan validate, and to anonymously shop all of your plans like a member would within both the federally-facilitated marketplace environment, as well as any state-based marketplace environment that you currently have today.

Now, while some people do spot check plans here and there, we do encourage you to do a full testing of every single plan within your portfolio to, number one, make sure your benefits are displaying correctly, whether it’s your PCP copays, specialist copays, even some of your additional benefits within your product, whether it’s a program or an incentive that you’re looking to offer a member.

We also encourage you to take a hard look at your rates to make sure your premium rates by county, or even zip code, are matching the way a member would search.

And if you do have time before 11/1, we do encourage you to bake in enough time to test to make sure providers are returning to certain results within the facilities that you’re covering, as well as certain prescription drugs are being covered when returned in the prescription drug directory, as well.

To make the most efficient testing process, we do recommend you wrap a timeline around this by developing a project plan. The beauty of developing a project plan this year will be this is an annual process, and it’ll be repeatable in the same time period next year, the following year, and the following year after.

And the really tricky part about healthcare.gov is in this transitionary period of the fall between your data being disposed with the State Divisions of Insurance, CMS, and then going live on healthcare.gov is the certification and approval process. Right now, as we move into the fall, closer to 11/1, while carriers still may be trying to make changes to their plan portfolio, it does have to go through the rigorous DCR, also known as data change request process.

So while carriers still may want to make last-minute changes through the DCR process up until 11/1, we encourage issuers not to make changes unless absolutely necessary, unless if it is a compliance change or a compliance risk to your product portfolio shelf for January 1 effective date.

We also recommend that if you do have time in advance of 11/1, once your shopping experience testing has concluded, that you do check all of your non-marketplace websites to ensure that any product data live out there, whether it’s internal to your own company landing pages or other partners or TPAs that you work with, are displaying your product and plan data correctly.

While the focus of these changes put forth by CMS are with healthcare.gov, issuers must not forget where all of their other data does display outside of healthcare.gov.

As we look to simplify healthcare for the members that we serve across the country, we do agree that these changes by CMS will be favorable to the user experience of enrolling into a qualified health plan, and we do expect to see more technical changes on healthcare.gov next year, as well.

Thanks again for listening to today’s episode. Give us a like, give us a share, and we’ll see you all next time.