Public Law 119-21 was signed on July 4, 2025, and its effects are phasing in between 2026 and 2028. Some changes are already in force and directly affect what you pay and when you can enroll. Here they are in order of urgency.
There are two dates, and confusing them costs a month without insurance. December 15 is the cutoff for your coverage to start on January 1. January 15 is the close of enrollment, but anyone who enrolls after December 15 isn't covered until February 1.
1. Two different dates, and confusing them costs a month without insurance
Enrollment opens on November 1. From there, what changes isn't so much the closing date as when your coverage starts:
- Up to December 15 → your insurance starts January 1.
- From December 16 to January 15 → you can still enroll, but coverage doesn't start until February 1. You spend January uncovered.
On top of that, the calendar is in the courts. A federal rule was going to close enrollment for everyone on December 15; a judge vacated it in June 2026 and the government appealed in July. Until it's resolved, the close remains January 15, but it could move again.
That's why my advice doesn't change with the lawsuit: enroll in November. That way you're covered from January 1 whatever the deadline turns out to be, and there's room to spare if a document is missing.
2. The enhanced subsidies are over
Since 2021 there were enhanced subsidies that made a great many families pay $0 or very little a month. They expired on December 31, 2025 and Congress did not renew them.
This brings back two things that had gone away:
- The "400% cliff": if your income exceeds 400% of the federal poverty level, you stop qualifying for any subsidy. There used to be a smooth transition; now it's a hard cutoff.
- The share of your income you're expected to pay goes up across every bracket.
The fact that premiums went up does not mean you no longer qualify for help. A great many families still receive a subsidy; what changed are the amounts. If you dropped your plan because you got a high price, it's worth recalculating before you end up with nothing.
3. If you miscalculate your income, you now repay everything
When you enroll, you estimate how much you'll earn during the year. Your advance subsidy is calculated from that estimate. If you ended up earning more, you had to pay some back — but there was a cap depending on your income.
Starting with tax year 2026 that cap is gone. If your actual income ends up above what you estimated, you repay the entire excess, with no limit, at tax time.
This changes how it has to be handled: estimating at enrollment is no longer enough. If you change jobs, get more hours or your business improves, the estimate has to be updated during the year. It's free and it avoids a nasty surprise in April.
4. Immigration requirements are changing
The law restricts who can receive federal help, and it affects two different programs:
| Program | What changes | Effective when |
|---|---|---|
| Health Marketplace (Obamacare) |
The tax credit is limited to permanent residents, migrants under the Compacts of Free Association, and Cuban/Haitian entrants. Those with TPS, asylum or refugee status stop qualifying for the subsidy. | Tax years beginning after December 31, 2026 |
| Medicare | Eligibility is restricted to those same groups. Anyone already enrolled who doesn't meet them would lose coverage, within 18 months of the law. | From enactment |
Some of these provisions have been challenged in court, so the situation may change. If you're in one of these groups, don't make decisions based on an article alone: get your specific case reviewed.
5. Your information will have to be re-verified every year
Starting with 2028 coverage, before your policy begins there will have to be verification of income, household size, immigration status, residence and whether you have other coverage available — even if nothing has changed since the previous year.
On top of that automatic renewal is ending. You'll be able to enroll, but you won't receive the tax credit until verification is complete. Translated: you have to be far more organized with your paperwork and not leave it for December.
Summary: what to do now
- Mark November 1 on your calendar. Don't wait for December, let alone January.
- Have your documents ready beforehand: ID, Social Security number and a realistic income estimate.
- Review your current plan even if you're happy with it. Prices and subsidies changed; it may no longer be the best option.
- Report it if your income changes during the year, now that there's no repayment cap.
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Sources
This article is general information and does not replace legal, tax or immigration advice. Some provisions of the law are being challenged in court and could change. For your specific situation, ask me directly or contact HealthCare.gov at 1-800-318-2596.