CMS Proposes Changes to ACA Enrollment Periods and Eligibility Verification

A Closer Look at the 2025 ACA Enrollment Reforms

The Centers for Medicare & Medicaid Services has proposed significant adjustments to the Affordable Care Act (ACA) enrollment process for 2025. These proposed reforms aim to tighten eligibility rules and reduce wasteful spending, but they may also narrow access for many low- and moderate-income individuals.

Shortened Enrollment Windows

Under the proposed rule, the ACA’s annual Open Enrollment Period (OEP) would run only from November 1 to December 15, rather than extending through January. CMS argues this shift would align enrollment timing with many employer-sponsored plans and Medicaid renewals, thereby promoting continuity of coverage. Critics, however, suggest that shortening the timeframe could confuse consumers or reduce uptake—particularly among first-time enrollees.

According to a recent CMS press release, the proposal is designed to "encourage timely decision-making while improving program integrity."

Special Enrollment Period Eliminations

Another major shift involves eliminating the Special Enrollment Period (SEP) available to individuals with incomes below 150% of the federal poverty level (FPL). This SEP currently allows low-income Americans to enroll at any time during the year. Removing it would mean many people would have to wait until the next OEP to gain coverage.

In their official Federal Register publication, CMS justifies this change by suggesting it will reduce “adverse selection” and encourage year-round coverage behavior. But critics—including several advocacy groups—warn this could disproportionately affect those who already struggle with coverage gaps.

Health policy researcher Karen Pollitz of KFF notes, “Enrollment flexibility is a lifeline for low-income individuals. Removing it will make that safety net a lot thinner.”

Stricter Eligibility Verification Requirements

CMS also proposes tightening income and SEP verification protocols, requiring state and federal marketplaces to verify at least 75% of new SEP applications before coverage begins. The rationale is clear: CMS estimates that enhanced verification could save between $11 and $14 billion by 2027 in improper federal spending on premium tax credits.

While intended to reduce fraud, these additional steps may present hurdles for consumers who lack easy access to documentation or experience difficulties navigating administrative systems. As noted by Justice in Aging, such policies can unintentionally exclude eligible individuals by making enrollment more burdensome.

ACA Enrollment Trend Snapshot

Source: Center on Budget and Policy Priorities

ACA marketplace enrollment has steadily increased over the past four years, reaching a record 21.3 million sign-ups for 2024. That momentum could stall if the proposed restrictions are enacted.

Potential Impact and Industry Response

According to experts at Health Management Associates, these changes may offer short-term administrative savings but could lead to long-term access challenges for vulnerable populations.

The proposed changes remain open for public comment through mid-June 2025. As stakeholders—ranging from insurance brokers to advocacy groups—weigh in, the final version may be revised or delayed.

CMS maintains that program integrity must be prioritized. Still, the trade-off may come at the expense of those least able to weather gaps in coverage.

Medical Disclaimer

The information provided in this article is for educational and informational purposes only and is not intended as medical advice. It should not be used to diagnose, treat, cure, or prevent any medical or mental health condition. Always seek the guidance of a qualified healthcare professional or licensed mental health provider with any questions you may have regarding a medical condition, diagnosis, or treatment. Never disregard professional medical advice or delay seeking it because of something you have read here.