In a nod to the political potency of the risk that enhanced Affordable Care Act (ACA) premium tax credits will expire at the end of 2025, a group of 10 House Republicans—joined by several Democrats—have offered legislation to extend the premium tax credits as they were enhanced in 2021 (during the COVID pandemic) for one year.

On September 4, the Department of Health and Human Services (HHS) issued new guidance on expanded eligibility for Affordable Care Act (ACA) catastrophic health insurance plans. The guidance provides that individuals who cannot get premium tax credits or cost-sharing reductions via a health insurance exchange can now qualify for hardship exemptions under the ACA that allow them to purchase catastrophic health insurance. The expanded eligibility takes effect November 1, according to HHS.

In Rev.Proc. 2025-2026, the Internal Revenue Service (IRS) announced inflation adjustment increases in the Affordable Care Act employer mandate penalties. The penalties are based on whether an applicable large employer (ALE) fails to offer affordable health insurance to at least 95 percent of its full-time employees and at least one of those employees receives a premium tax credit to buy individual health insurance. An ALE is an employer with 50 or more full-time equivalent employees. Affordability is measured by employee contributions to the cost of their employer-provided health care—penalties attach if those contributions exceed maximum percentages of their compensation.

The enhanced Affordable Care Act (ACA) premium tax credits that were enacted during the COVID epidemic lock-down expire at the end of 2025. Efforts to extend them, and other expiring health insurance rules, could drive a new tax bill this fall.

The Internal Revenue Service (IRS) has announced the 2026 inflation adjustment for determining the affordability of employer-provided Affordable Care Act (ACA) health insurance. For 2026, the affordability standard will be 9.96 percent of a worker’s compensation. Failure to adhere to the affordability standard results in a “shared responsibility” penalty imposed on employers.

On June 20, the Centers for Medicare and Medicaid Services (CMS) issued a final rule (RIN 0938-AV61) that reduces by two weeks the time period during which individuals can enroll in Affordable Care Act (ACA) exchange-based health insurance plans. The rule also eliminates the ability of people with incomes of less than 150 percent of the federal poverty level to enroll in monthly ACA coverage.

If, as expected, the GOP controls both the House and Senate next year, the risks and challenges of the 2025 tax bill have become a bit clearer. Here is a run-down.

Incoming President-Elect Donald Trump’s Administration is likely to roll back a plethora of regulations of concern to NAIFA members and their clients.

The premium tax subsidies that allow lower-income individuals to get Affordable Care Act (ACA) health insurance free or at reduced cost are scheduled to expire at the end of 2025. If the current subsidies do expire, millions of low-income individuals will face significant health insurance cost increases. Extension of the subsidies will be a key issue in the 2025 tax bill and/or during the November-December lame-duck session of the 118^th Congress.

On October 5, the Centers for Medicare and Medicaid Services (CMS) released its proposed rules for Affordable Care Act (ACA) health insurance for 2026. The rules cover agent/broker practices.

On July 25, Senate Finance Committee Chair Sen. Ron Wyden (D-OR), along with five colleagues, introduced legislation that would impose criminal penalties on “rogue” health insurance advisors who make changes to individuals’ Affordable Care Act (ACA) health insurance without the insureds’ knowledge or consent. The Insurance Fraud Accountability Act would impose fines on brokers who negligently provide incorrect enrollment information, and criminal liability if the provision of incorrect information is “knowingly and willfully false or fraudulent.”

On March 28, the Departments of Labor (DOL), Health and Human Services’ (HHS’) Centers for Medicare and Medicaid Services (CMS), and Treasury released a final short-term limited-duration (STLD) health insurance rule. It retains the proposed rule’s new limits of three months duration, with a four-month renewal option for this kind of insurance.

The Centers for Medicare and Medicaid Services (CMS) has announced new cost-sharing limits and required contribution percentages for the 2025 benefit year. For the 2025 calendar year, the self-only coverage annual limitation on cost-sharing is $9,200. It is $18,400 for other than self-only coverage.