Employee Experience After ACA Subsidy Expiration

Open enrollment used to be a once a year event. Now it is a year round conversation, and the stakes just got higher.

The enhanced ACA premium tax credits expired at the end of 2025, and the effects are already showing up in 2026 marketplace data.

• Average deductibles grew by roughly $1,000 per person, and more enrollees shifted into higher deductible plans as the subsidies disappeared.¹

• The Congressional Budget Office projects individual market premiums will rise an additional 4.3 percent in 2026 because of the expiration, with a further 7.7 percent increase expected in 2027.²

• Millions of people are expected to lose coverage entirely.³

For HR teams and the brokers who support them, this is not an abstract policy shift. It’s a direct hit to employee experience.

Affordability concerns are rising, confusion is rising with them, and the way benefits are communicated this year will shape trust for years to come.

Affordability is now an employee experience issue

Benefits used to be evaluated on cost and coverage. Now employees are evaluating them on clarity too. When marketplace premiums jump and subsidies shrink, employees start asking harder questions about what their employer offers and why.

A few things are converging at once.

• Employees who previously relied on marketplace subsidies may now be looking to their employer for a more affordable path to coverage.

• Legal experts anticipate employee demand for employer sponsored benefits will increase as individual market premiums become harder to absorb.⁴

• HR teams are fielding more questions, and often with less lead time than they had in past years.

This is where the conversation about choice becomes central. An employer could pick the technically right benefit model for 2026 and still leave employees feeling confused or unsupported if the surrounding experience isn’t handled deliberately.

What HR teams should do differently this year

Reconsider whether the current benefit model still fits, given this specific shift.

This doesn’t mean overhauling benefits reflexively. It means evaluating the decision against this year’s numbers rather than assuming last year’s plan design still holds up now that the subsidy landscape has changed.

Across our 2026 Take Command survey, one theme surfaced repeatedly. Employees do not just want a benefit. They want options that fit their actual life, whether that means a specific doctor, a particular plan type, or a level of coverage that matches their household.

That’s part of why interest in ICHRA is climbing this year specifically, as employers look for a way to respond to rising individual market costs without locking everyone into the same group plan. ICHRA gives each employee a defined contribution to shop the individual market and choose a plan that works for them. That flexibility is a meaningful part of why interest in ICHRA keeps growing among employers who are rethinking their benefits strategy this year.

A few things worth keeping in mind before making that call:

• ICHRA isn’t automatically the cheaper option for every employee this year, and it isn’t the right fit for every workforce. Depending on someone’s age, location, and health needs, a traditional group plan premium can still come out lower for that individual, even with marketplace premiums rising.

• What ICHRA more reliably offers is a predictable cost structure for the business at a moment when group renewals are also unpredictable.

• The point isn’t that ICHRA is automatically the right response to subsidy expiration. It’s that it’s one strategic option worth validating against your specific population’s 2026 numbers, compared honestly to a traditional group plan or level-funded alternative, rather than assuming any one model is the obvious answer this year.

Build decision support around this year’s questions, not just a bigger menu.

Giving employees a budget and a marketplace isn’t the same as giving them a plan. That gap matters more this year because employees have new, urgent questions about what subsidy expiration means for them specifically. A few things make the biggest difference:

• Plain-language education that addresses subsidy expiration directly, delivered before enrollment opens, not during it, so people aren’t learning what changed under a deadline.

• Personalized plan comparison tools that show real 2026 numbers based on an employee’s own situation, not last year’s examples.

• A clear point of contact for questions about how this year’s changes affect them, whether that’s HR, a broker, or a dedicated support team.

• Reminders built around this year’s key dates, so employees aren’t scrambling at the last minute or missing a window because they assumed nothing had changed.

None of this requires a massive overhaul. It requires intention now, and a plan that starts well before enrollment opens.

Communicate changes to benefits deliberately.

A benefit that’s well suited to this year’s environment can still land poorly if employees aren’t told why it’s different from last year. Employees who feel blindsided by a change, even a genuinely good one, tend to respond with frustration rather than curiosity.

A few principles hold up for this year’s rollout:

• Explain the why before the what. Connect any change directly to subsidy expiration so employees understand it’s a response to a real shift, not a change for its own sake.

• Address affordability head on. Employees are already anxious about cost because of what’s happening with marketplace subsidies right now. Naming that directly builds trust rather than avoiding the topic.

• Give people time to process. A single email announcement rarely suffices for a change tied to something as significant as subsidy expiration.

• Create space for questions specific to this year’s situation, and make sure someone is actually equipped to answer them in detail, not just point to a generic PDF.

What brokers should do differently this year

Brokers are often the first line of defense when a client’s employees have questions or concerns. Subsidy expiration gives brokers a natural, timely reason to check in with clients this year, even ones who aren’t actively shopping for new coverage.

A few things separate the brokers who add real value in this moment from the ones who don’t:

• Understand the client’s specific employee population. This matters more than defaulting to a familiar recommendation, because a younger, lower-income workforce and an older, higher-income one are feeling this year’s premium increases very differently.

• Bring real 2026 numbers, not just general talking points. Employers may have heard about ICHRA or other alternatives in the abstract before. What actually moves things forward now is a comparison built around their own renewal numbers and how subsidy expiration is affecting their specific employees.

• Name tradeoffs honestly. Clients are looking for direction, not just plan options. Brokers who walk employers through the affordability tradeoffs of ICHRA versus traditional group coverage, with real numbers instead of general talking points, become the trusted advisor rather than just the vendor.

Just as important is what happens after a decision gets made. A plan recommendation without a communication strategy for explaining this year’s changes leaves the employer to figure out messaging on their own, which is often where things go wrong even when the underlying decision was sound.

And employee questions about affordability won’t stop once a plan is selected, not with premiums still expected to climb again in 2027. Brokers who stay engaged through the year, not just through this enrollment season, are the ones clients remember.

Moving forward together

Subsidy expiration has changed the calculus for a lot of employees, and that ripple effect is landing squarely on HR teams and the brokers who support them. The good news is that the tools to respond well already exist. Choice, paired with real decision support and honest communication, gives employees a benefits experience that feels less like a mandate and more like a genuine option built around their needs.

The businesses and brokers who take the time to validate what actually works, rather than assuming one model fits every situation, are the ones who will come out of this year with stronger trust and fewer surprises.

HR professionals: see how ICHRA can support your team’s affordability and choice goals. Explore HRA solutions for HR professionals

Brokers: help your clients navigate this shift with confidence. Learn more about ICHRA for brokers

References

1. KFF. “What We Know So Far About 2026 ACA Marketplace Enrollment, Premiums, and Deductibles.”

2. Congressional Research Service via Congress.gov. “Enhanced Premium Tax Credit and 2026 Exchange Premiums: Frequently Asked Questions.”

3. Urban Institute and the Commonwealth Fund. “4.8 Million People Will Lose Coverage in 2026 if Enhanced Premium Tax Credits Expire.”

4. Ogletree Deakins. “Enhanced ACA Health Insurance Subsidies Likely to End.”