Let Your ACA Plan Auto-Renew? Starting With 2028 Coverage, Your Subsidy Wouldn't Renew With It.

If you’re one of the millions who never log back into HealthCare.gov and just let the plan roll over, Washington wants to end that, at least for your subsidy. Under a proposal published October 27, starting with 2028 coverage you’d have to confirm your details every year or get re-enrolled at full price.

The average subsidy CMS uses in its math is $655 a month. Miss the window and that’s what your January bill could jump by.

You don’t need to do anything for 2027. File this away, and do one thing before Thanksgiving.

What’s changing

The 2025 tax law the administration calls the Working Families Tax Cuts says the premium tax credit can’t be paid until your eligibility is verified, starting in 2028. CMS’s proposed rule is how the marketplaces would carry that out.

Two pieces matter. First, the free pass ends. Today, if the marketplace can’t match your income to IRS data, you keep your subsidy for the inconsistency period while you send pay stubs. Under the proposal, you’d either pay full price until you’re verified, with the subsidy credited back for the months it can confirm, or pick a plan that only starts once you’re cleared.

Second, auto-renewal with a subsidy ends. Every year between August 1 and December 31, you’d have to provide or confirm your income, family size, citizenship or immigration status, other coverage and address. Skip it and you’re “automatically re-enrolled without financial assistance,” in CMS’s words.

How many people does that touch? CMS counts 3,969,403 people on the federal platform and 1,703,494 on state marketplaces who renew today without contacting anyone. That’s about 5.7 million.

The math

The case for this is real. We wrote about the 760,000 people dropped after brokers enrolled people without permission. Checking income before handing out $655 a month is not an outrageous ask.

Here’s the catch for honest enrollees. CMS estimates about 5.1 million people a year would go an average of 1.5 months without the subsidy while paperwork clears. At $655, that’s about $980 you front or go without. It also expects 332,500 people to drop coverage over the hassle, mostly younger and healthier, nudging premiums up an estimated 0.4% for everyone left.

And if a full-price bill lands and you can’t pay it, CMS itself says you can be dropped for nonpayment and locked out until a qualifying life event or the next open enrollment.

Verdict: a fair rule with a nasty trap for anyone on autopilot.

Do this now

Comment by November 27. Go to Regulations.gov docket CMS-2026-3367 and tell CMS what verifying your income actually takes, especially if you’re self-employed or your hours swing. Proposals change when real people show up with specifics.

Log in during this open enrollment anyway. Your 2027 renewal still rolls over under today’s rules, but an out-of-date income estimate is how you end up paying back your subsidy with no cap. Put your real number in now.

Then set a reminder for August 1, 2027, and start a folder: pay stubs, a profit-and-loss sheet if you freelance, and last year’s return. Use our budget planner to see whether a full-price month or two would break you.

The detail

This is a proposal, not a final rule. It also lets you skip the new verification for some family-size changes after a birth, adoption, marriage, divorce or death, and requires every marketplace to open the early window on August 1 each year. The rule is CMS-9873-P, published at 91 FR 67656.

How Candid Yak makes money. Some of the products we write about pay us if you apply or sign up through our links. That never changes our verdict, our rankings, or the numbers in this article. We call a bad deal a bad deal whether it pays us or not. Some brands shown in our comparison tools are placeholder examples while we finalize partner agreements, and we label them as such.