By Amy Killelea, Madison Harden-Stein, and JoAnn Volk
For consumers shopping for Affordable Care Act (ACA) Marketplace coverage, 2026 has brought new challenges. The expiration of enhanced premium tax credits (ePTCs) at the end of 2025 led to higher premiums for virtually all Marketplace enrollees, with especially significant increases for older and middle-income consumers. At the same time, federal policy changes have expanded access to health coverage products that are not subject to the ACA’s comprehensive coverage standards and consumer protections.
Amid these affordability challenges, consumers may be increasingly vulnerable to misleading marketing tactics. A new secret shopper study from the Center on Health Insurance Reforms (CHIR) at Georgetown University’s McCourt School of Public Policy examines how agents and brokers market health coverage options to consumers navigating this complex landscape.
Conducted in May 2026, the study used two consumer profiles to assess interactions with 20 sales representatives. The findings build on previous CHIR secret shopper studies conducted in 2019, 2021, and 2023, showing continued concerns about how limited benefit products are marketed to consumers.
The study found that:
- Online searches led consumers to “lead generators,” whose websites used marketing emphasizing major medical plan options; lead generators then handed off consumers to agents and brokers.
- Sales representatives often portrayed ACA Marketplace plans as an option primarily for people with significant health needs, steering healthier consumers toward non-ACA-regulated products.
- Agents and brokers provided misleading or inaccurate information about limited benefit products—including fixed indemnity insurance, short-term limited-duration insurance, and other limited benefit plans—as well as Marketplace coverage.
- Sales representatives capitalized on consumers’ affordability concerns, promoting products that may not provide meaningful protection from high health care costs.
These findings highlight the challenges consumers face when trying to make informed decisions about health coverage, and underscore the need for stronger state and federal oversight of marketing practices and limited benefit products.
Read the full report here to learn more about the study’s findings and policy implications.
