FEDERAL POLICY CHANGES

Important Changes to Health Insurance

Recent congressional action is bringing changes to the health insurance industry, impacting how you apply for or renew your coverage, how much it costs, and who is eligible. The changes will go into effect over the next three years. We encourage you to work with a certified agent or broker to ensure you have the information you need on the requirements that may affect you.

These professionals are current on Your Health Idaho policies and ready to help navigate the process or answer questions. Their assistance is available at no cost. Click here to find a local agent.

It’s important to note that the changes do not affect your 2025 health coverage. If you’re currently enrolled, we encourage you to use your benefits. Whether it’s scheduling your annual wellness visit or addressing a concern you’ve been putting off, now is the time to take charge of your health.

One of the most impactful changes for 2026 is the expiration of the enhanced Premium Tax Credits (ePTC), which are scheduled to expire on December 31, 2025. ePTCs were put into place with the American Rescue Plan Act (ARPA) in 2021 to further lower the cost of monthly health insurance premiums. If there is no congressional action to renew ePTCs, the Advance Premium Tax Credits will revert to the original formula, with the following results:

• • Idahoans’ tax credit will be reduced, so they’ll pay more each month for their health insurance premiums
  • Idahoans over 400% of the Federal Poverty Level (FPL) will no longer be eligible to receive an Advance Premium Tax Credit (APTC)

Verifying Income

(Effective Date: August 25, 2025)

Your Health Idaho can no longer accept the income that a consumer attests to on their application when:

• The income verified through federal sources is below 100% of the Federal Poverty Level (FPL)
• The income can’t be verified through Federal sources because of a lack of data (for example, if a consumer has never filed income taxes)

For those cases, consumers will need to provide proof of income to Your Health Idaho.

Providing Documentation

(Effective Date: August 25, 2025)

When the income reported on an application doesn’t match the data available through other sources (for example, the IRS), documentation must be submitted within 90 days. Previously, there was an automatic 60-day extension; that extension has been removed.

Below 150% FPL Special Enrollment Period 

(Effective Date : August 25, 2025)

Earning less than 150% of the Federal Poverty Level (FPL) is no longer a Qualifying Life Event (QLE) to open a Special Enrollment Period and enroll in health insurance. Idahoans seeking coverage who fall under 150% FPL will have to wait until Open Enrollment or experience an approved QLE to enroll in coverage outside the Open Enrollment period.

Enhanced Premium Tax Credits Expire

(Effective Date: December 31, 2025)

Advance Premium Tax Credits offered through the Affordable Care Act will remain in place. However, the enhanced Premium Tax Credits (ePTCs) introduced in 2021 expire on December 31, 2025.

Requirement to Reconcile Advance Premium Tax Credits

(Effective Date : January 1, 2026)

Consumers who receive an Advance Premium Tax Credit (APTC) are required to reconcile the tax credit each year on their federal income tax return in order to remain APTC eligible. Failure to reconcile annually will now result in the loss of tax credit eligibility for the following plan year.

End of Advance Premium Tax Credits Repayment Cap

(Effective Date: January 1, 2026)

Consumers who receive excess Advance Premium Tax Credit (APTC) because their income at the end of the year is greater than the income on their application will need to repay the full amount of the excess tax credit received. In the past, that repayment was capped based on income.

While we strongly encourage Idahoans to update their income and other changes throughout the year, it’s important to note that updating income can result in what’s called APTC Rebalancing. This is when the tax credit amount adjusts because of the income change; the monthly premium cost will then also change to reflect the new tax credit amount.

Consider Your Options (APTC Recapture vs APTC Rebalancing)

Idahoans receiving a tax credit whose income has increased should understand the impacts before taking action. They need to determine if they want to continue with their current APTC, at the risk of needing to pay back the excess amount when they file their taxes. That’s called APTC Recapture. The second option is to report their income change as required, which may lower their tax credit and increase the amount they pay each month for the rest of the plan year (APTC Rebalancing).

Click here to see an example of Recapture vs Rebalancing.

Immigration Eligibility and Classification Change (Part 1)

(Effective Date: January 1, 2026)

Immigrants UNDER 138% of the Federal Poverty Level (FPL) are no longer eligible for an Advance Premium Tax Credit (APTC) and will be renewed for plan year 2026 without a tax credit.

Removal of Advance Premium Tax Credit Eligibility During Medicaid Five-Year Bar

(Effective Date: January 1, 2026)

People who are in the Medicaid waiting period, known as the “five-year bar” because of their immigration status, are no longer eligible for an Advance Premium Tax Credit.

High-Deductible Health Plans (HDHPs)

(Effective Date: January 1, 2026)

Individual plans classified as Bronze and Catastrophic through the Marketplace are now defined as High-Deductible Health Plans (HDHPs) and are eligible to be paired with a Health Savings Account (HSA).

Immigration Eligibility Change (Part 2)

(Effective Date : January 1, 2027)

Eligible immigrants now include:

• Lawful permanent residents/Green Card holders
• Cuban and Haitian entrants
• Citizens of the Marshall Islands, Micronesia, and Palau who are living in one of the U.S. states or territories

Non-eligible immigrants OVER 138% of the Federal Poverty Level (FPL) no longer qualify for an Advance Premium Tax Credit (APTC) and will be renewed for plan year 2027 without a tax credit.

Eligible immigrants no longer qualify for the Advance Premium Tax Credit (APTC) during the five-year waiting period for Medicaid.

End of Passive Advance Premium Tax Credit Auto-Renewals

(Effective Date: August 1, 2027)

Your Health Idaho can no longer renew Idahoans for the next plan year with an Advance Premium Tax Credit (APTC) or Cost-Sharing Reductions (CSRs) until they verify their application information. A consumer who does not verify their information will be renewed as “non-financial,” meaning without a tax credit.

Consumers can verify their information for the 2028 plan year beginning in August 2027. Those who are renewed as non-financial need to review and update the information in their application. Once it’s submitted, it will be re-processed to determine and apply their tax credit amount for 2028.

To remain eligible for APTC and CSRs, Idahoans must verify their information each year before January 1, and can begin as early as August 1.

Eligibility Verification Requirements for SEPs

(Effective Date: January 1, 2028)

In the case of a Special Enrollment Period (SEP), a consumer’s eligibility must be verified before being awarded an Advance Premium Tax Credit (APTC). If additional documentation is needed because of a data matching issue, consumers can enroll in a full-priced plan, and the tax credit will be backdated when the verification is complete. The only exception is an SEP for a change in family size.