ACA Agent Guide

The Marketplace, explained agent to agent.

Metal tiers, subsidies, enrollment windows, and the compliance rules that actually apply on the ACA side — not the Medicare side. Built for Time Financial Group's ACA-appointed agents only.

B · S · G · P
Metal Tiers
Jan 1, 2026
Enhanced PTC Expired
400% FPL
Subsidy Cliff Is Back
Original ACA Structure

The four metal tiers

Every ACA Marketplace plan is one of four tiers (plus Catastrophic for a narrow group). The tier doesn't describe quality of care — it describes the split between premium and out-of-pocket cost.

B
~60% Actuarial Value

Bronze

Lowest premium, highest deductible and out-of-pocket costs. Good fit for someone who wants catastrophic-style protection and rarely uses care — 2026 average bronze deductible is $7,186.

  • Actuarial value~60%
  • PremiumLowest of the four tiers
  • 2026 avg. deductible$7,186
S
~70% Actuarial Value

Silver

The benchmark tier — premium subsidies (PTC) are calculated against the second-lowest-cost Silver plan in every area. It's also the only tier where Cost-Sharing Reductions (CSR) can apply.

  • Actuarial value~70%
  • CSR eligibleYes — Silver only
  • 2026 avg. deductible$5,304
G
~80% Actuarial Value

Gold

Higher premium, lower deductible and copays. Fits someone who expects to use care regularly and wants to pay more predictably rather than pay a large deductible first.

  • Actuarial value~80%
  • PremiumHigher than Silver
  • Best forFrequent or predictable care needs
P
~90% Actuarial Value

Platinum

Highest premium, lowest out-of-pocket costs. Rarely available in every county — availability varies significantly by state and carrier.

  • Actuarial value~90%
  • AvailabilityLimited — not offered everywhere
  • Best forHeavy, predictable utilization
Agent rule Never tell a client a metal tier is "better" in the abstract. The right tier depends on their expected utilization and their ability to absorb the deductible — walk through both, don't default to whichever has the lower headline premium.
The Single Biggest Change for 2026

Premium Tax Credits — and the subsidy cliff is back

The enhanced Premium Tax Credit (the ARPA/IRA "enhanced PTC") expired January 1, 2026. The original ACA subsidy structure did not disappear — it just reverted to its pre-2021 rules. That reversion is the thing to actually understand.

Status as of this writing: unresolved in Congress. The House passed a 3-year extension on January 8, 2026; the Senate had not passed it as of the most recent information available. Check current status before quoting a client — this could change with very little notice. Track the bill ↗
✓ Confirmed for 2026

What actually reverted

  • Income cap (subsidy cliff)Returns at 400% FPL
  • 100–150% FPL householdsMust contribute again (no longer $0)
  • Applicable % tableReverts to pre-2021 ACA schedule, re-indexed
  • Avg. premium impact+114% / ≈ $1,016 per year
Base PTC (100–400% FPL) still exists — it was never repealed. Only the ARPA/IRA enhancement lapsed.
Still moving — watch this

What could still change

  • 3-year extensionPassed House, stalled in Senate
  • Alternative Senate proposalsShorter extension + income caps / min. premium
  • Possible vehicleAppropriations bill or reconciliation package
If something passes retroactively, re-run any client's numbers before assuming last quarter's figures still hold.
Agent rule Do not quote a client's subsidy from memory or from what it was last year. Run the actual APTC estimate through the Marketplace or your EDE platform every time — the applicable percentage table changed for 2026, and if income sits near 400% FPL, a small error puts them over the cliff into paying full price.
Separate From PTC — Don't Confuse Them

Cost-Sharing Reductions (CSR)

CSRs lower deductibles, copays, and coinsurance — not the premium. They were not affected by the enhanced-PTC expiration; they're a separate provision with their own eligibility rule.

How it actually works

CSR is only available on a Silver plan. A household between 100% and 250% of FPL who enrolls in Silver automatically gets a CSR variant of that plan — same premium, meaningfully lower deductible and out-of-pocket costs. Moving them to Bronze or Gold to save on premium forfeits the CSR entirely, even if they'd still qualify by income.

Because of this, a lower-income client is very often better served by Silver than by Bronze, even though Bronze looks cheaper on the surface — CSR is where a lot of the real value sits for that income band.

  • Who qualifies100–250% of FPL, and only if enrolled in a Silver plan.
  • What it doesn't touchThe premium itself — that's the separate PTC calculation.
  • Common mistakeSteering a CSR-eligible client to Bronze for a lower premium, without flagging what they're giving up.
Timing Matters

When clients can enroll or make changes

Unlike Medicare, the ACA Marketplace has one national Open Enrollment window plus event-triggered Special Enrollment Periods — no MA-style annual switch window.

Nov 1 – Jan 15 (most states)

Open Enrollment Period (OEP)

The one guaranteed window every year. Enroll, switch plans, or drop coverage for any reason. Coverage starting Jan 1 generally requires enrolling by Dec 15. Some State-Based Marketplaces run a longer window — confirm the state's actual dates.

Event-Triggered

Special Enrollment Period (SEP)

Loss of other coverage, marriage, birth or adoption, a permanent move, a change in income that affects subsidy eligibility, and several other qualifying events. Most SEPs give 60 days from the event to enroll.

Ongoing

Income-Based SEP (≤150% FPL)

Households at or below 150% of FPL can enroll or switch plans monthly, year-round — not limited to OEP or a qualifying event. Worth checking for lower-income clients who missed OEP.

Year-Round

Medicaid / CHIP Enrollment

Medicaid and CHIP have no enrollment period restriction — eligible individuals can apply any time. If someone's income lands them under 100% FPL (and their state expanded Medicaid), that's Medicaid territory, not a Marketplace plan.

Agent rule Verify every SEP against an actual qualifying event and its documentation requirement before submitting an application. "They want to enroll" is not itself a qualifying event.
2026 Figures

2026 costs at a glance

Averages nationally — actual numbers vary heavily by state, carrier, and age. Always confirm the specific plan's numbers before quoting.

Item2026 FigureNote
Avg. Silver deductible $5,304 Before any CSR reduction
Avg. Bronze deductible $7,186 No CSR available on Bronze
Avg. premium increase +114% (≈ $1,016/yr) Driven by enhanced-PTC expiration
Subsidy cliff 400% FPL Back in effect for 2026
Sources: KFF Health System Tracker (Jan 2026), CBPP, IRS 2026 required-contribution percentages. Figures are national averages — confirm the specific plan and state before quoting a client.
ACA Agent/Broker Rules — Different From TPMO

Compliance basics for the ACA side

The Medicare TPMO framework doesn't apply here — the ACA Marketplace runs on its own CMS registration, training, and consent rules. Don't assume Medicare compliance habits automatically cover you.

Marketplace registration & training

Agents must complete annual CMS Marketplace Learning Management System (MLMS) training and registration before assisting consumers with Marketplace coverage — separate from any Medicare AHIP certification.

Enhanced Direct Enrollment (EDE)

If you're enrolling through an EDE-approved partner platform rather than directly on Healthcare.gov, that platform has its own consent, display, and audit requirements layered on top of the base CMS rules.

Consent to contact

Get and document consent before contacting a consumer about Marketplace coverage. A prior Medicare PTC or SOA does not carry over to authorize ACA-related contact — they're separate consents for separate lines of business.

No cold calling

Same underlying principle as the Medicare side: outbound contact needs a documented lawful basis (referral, prior consumer-initiated contact, or approved lead source) — not an unsolicited call from a purchased list.

Navigator vs. Agent/Broker

Navigators are grant-funded, cannot receive commission, and must remain plan-neutral. You are commissioned and represent specific carriers — never present yourself as a Navigator or as a neutral government resource.

Accurate plan comparisons

You don't have to show every plan in the market, but any comparison you do show must be accurate as of that day — provider networks and formularies change plan-year to plan-year just like on the Medicare side.

Agent rule Confirm your Marketplace registration and required training are current for the plan year before taking any ACA case — an expired MLMS registration is a hard stop, not a technicality.
New for PY2027. CMS requires EDE platforms to implement new identity-proofing and agent/broker authorization controls (CR 109) no later than October 12, 2026, ahead of OEP 2027. This is layered on top of — not a replacement for — the existing consumer consent requirement below.

EDE authorization & identity proofing (CR 109)

All EDE agent/broker-pathway applications now require agent/broker authorization. The platform itself blocks you from proceeding until it's completed — this isn't optional guidance, it's enforced in the software. High-risk cases (new applications, a consumer working with a different/new agent, or an existing enrollment with a net premium of $30 or less after APTC) require consumer identity proofing before agent/broker authorization. Low-risk cases can use a lighter mechanism like a one-time passcode or confirmation link. Authorization is generally plan-year specific — gather it again each year, don't assume last year's carries forward.

OEP 2027 dates & the Call Center change

OEP 2027 on the federal platform runs November 1 – December 15, 2026; coverage selected begins January 1, 2027. Starting with this OEP, the Marketplace Call Center no longer supports application or enrollment changes requested by an agent/broker — the new EDE authorization flow is meant to replace what used to require a three-way call. If the platform blocks an action, follow its approved instructions rather than assuming the old three-way-call option is still there.

Zero shortcuts on contact info & identity

The consumer or authorized representative must directly control the email and phone number on the application — never substitute an agent, agency, or placeholder contact to force an application through. Separately, CMS now requires CMS-verifiable Social Security Numbers or immigration document numbers for all non-newborn applicants on agent/broker-assisted applications; if a consumer can't provide or verify required info, use the Marketplace's resolution process instead of guessing.

2028 note — don't implement early

CMS has finalized mandatory use of an HHS-created standardized consumer-consent and eligibility-application-review form — but only for plan years beginning January 1, 2028 or later. The existing consent and review-documentation rules apply through PY2027. Don't tell a consumer or a new agent that the standardized form is required yet.

Agent rule An unrecorded verbal "yes" by itself is not enough documentation that a consumer reviewed and confirmed their application. Acceptable documentation includes a signed document, a recorded verbal confirmation, a written electronic response, or another CMS-permitted method that actually meets the requirement — and it still has to be retained for at least 10 years.
Quick Reference

Glossary: ACA terms every agent should know cold

The shorthand you'll hear on every ACA call and training — defined once, in plain language.

PTC Premium Tax Credit
The base ACA subsidy that lowers a household's monthly premium, available between 100–400% of FPL. Calculated against the benchmark Silver plan.
Enhanced PTC ARPA/IRA subsidy boost
The temporary expansion that removed the 400% FPL income cap and increased subsidy amounts. Expired January 1, 2026.
CSR Cost-Sharing Reduction
Lowers deductibles and copays (not premium) for 100–250% FPL households enrolled in a Silver plan specifically.
FPL Federal Poverty Level
The income benchmark used to determine PTC and CSR eligibility. Updated annually; subsidy eligibility is expressed as a percentage of it.
MAGI Modified Adjusted Gross Income
The income figure actually used to calculate subsidy eligibility — not gross income or take-home pay.
Benchmark Plan 2nd-lowest-cost Silver
The second-lowest-cost Silver plan in a given area — the reference point the PTC amount is calculated against, regardless of which plan the client actually picks.
Subsidy Cliff 400% FPL cutoff
The point above which a household receives no PTC at all. Eliminated by the enhanced PTC 2021–2025; back in effect for 2026.
QHP Qualified Health Plan
Any plan certified to be sold on the ACA Marketplace, meeting Essential Health Benefits and other ACA requirements.
Metal Tier Bronze/Silver/Gold/Platinum
Categorizes plans by actuarial value (the average share of costs the plan covers) — not by network quality.
Actuarial Value AV
The average percentage of total costs a plan is designed to cover for a standard population — 60% Bronze up to 90% Platinum.
OEP Open Enrollment Period
Nov 1 – Jan 15 in most states — the one guaranteed annual window to enroll or change plans for any reason.
SEP Special Enrollment Period
A window opened by a qualifying life event — loss of coverage, marriage, birth, a move, or a subsidy-affecting income change. Typically 60 days.
EDE Enhanced Direct Enrollment
CMS-approved third-party platforms (not Healthcare.gov itself) that agents can use to quote and enroll clients, with their own added consent/audit rules.
CR 109 EDE authorization requirement
The CMS change requiring agent/broker authorization — and, for high-risk cases, consumer identity proofing first — before an agent can proceed on an EDE platform. Enforced by the platform itself, separate from and in addition to consumer consent. Required no later than Oct 12, 2026.
Navigator Not the same as an agent
Grant-funded, uncommissioned, plan-neutral assister. Distinct from a commissioned agent/broker — never blur this distinction with a client.
SBM State-Based Marketplace
A state-run exchange (instead of Healthcare.gov) with its own enrollment dates, rules, and sometimes its own subsidy add-ons.
Silver Loading Rate-setting strategy
A pricing practice where carriers price CSR costs entirely into Silver-tier premiums, which can make Gold plans unusually cheap relative to Silver for subsidized enrollees — worth checking every area, not assuming.
1095-A Marketplace tax form
The form the Marketplace issues showing months of coverage and subsidy received — needed to reconcile actual vs. estimated PTC on the client's tax return (Form 8962).
Form 8962 PTC reconciliation
The IRS form reconciling advance PTC paid during the year against the PTC the household actually qualified for based on final income — can result in owing money back or getting more credit.
MLMS Marketplace Learning Mgmt System
CMS's training and registration platform agents must complete annually to assist consumers with Marketplace coverage.
Essential Health Benefits EHB
The 10 categories of coverage every ACA-compliant plan must include — from emergency care to maternity to prescription drugs.

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For Time Financial Group Agents Only

Internal ACA agent tools

Where the actual sales process and application walkthrough live — not external resources, your own working tools.

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Interactive · Bilingual

ACA Sales Script

The step-by-step guided sales flow — gathering information, quoting, presenting options, and closing — with built-in compliance guardrails and a client information sheet.

Open ACA Sales Script ↗
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Interactive · Bilingual

HealthSherpa Application Guide

The complete 23-step walkthrough for submitting an ACA application in HealthSherpa, from login and consent through enrollment verification.

Open HealthSherpa Guide ↗
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Video · AllAccess

HealthSherpa Training & Quoting Webinar

Recorded walkthrough covering HealthSherpa training and live quoting, hosted on the AllAccess platform.

Open Webinar ↗
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Google Sheet · Internal

Client Tracker

Track client status and follow-ups across the ACA sales process.

Open Client Tracker ↗