HealthCare.gov and the state-based public health insurance supermarkets look as if they are operating normally and should be ready for the Affordable Care Act open enrollment period, which starts Nov. 1, in spite of the partial shutdown of the federal government that began Tuesday.
Lindsey Miller, the health care strategy director at Softheon, a software company that works with public exchange plans and other health coverage distributors, gave that assessment today in an email.
"HealthCare.gov continues to work as expected," Miller said. "I've not seen any disruption to its operations."
Miller has not noticed any state-based exchanges facing shutdown problems or other problems.
"All of the state-run exchanges we work with appear to be on track for a normal open enrollment," Miller said.
What it means: Turmoil at the ACA public exchange system could cause problems for any employers or benefits firms trying to set up or use individual coverage health reimbursement arrangement plans or qualified small employer HRAs in 2026.
Extreme turmoil at the ACA exchange system could distract health insurance company executives and reduce the executives' ability to address employers' health coverage concerns.
Affordable Care Act exchange basics: The ACA exchange system came to life in 2014.
It helps people shop for individual, family and small-group health coverage and use federal premium tax credit subsidies to pay for the subsidies.
Twenty states and the District of Columbia will run their own ACA exchanges for the 2026 coverage year, and 30 states will use HealthCare.gov, the exchange the U.S. Department of Health and Human Services set up to provide exchange services for residents of states that are willing or unable to operation exchange programs themselves.
HHS often calls HealthCare.gov and related operations "the Marketplace."
The shutdown backdrop: The federal government has a fiscal year that runs from Oct. 1 through Sept. 30.
The appropriation legislation that allows the government to spend money on its operations expired Tuesday.
Some federal government agencies can keep running normally because they fund their own operations by collecting fees or other payments.
Other government agencies can keep running because they get funding from legislation other than the main federal government funding appropriation.
Some agencies now have no funding that they can use to pay employees, but they are making employees come to work anyway, because the government classifies those employees' work as essential to protect Americans' safety.
Still other federal employees are on furlough and have no guarantees that they will be able to return to their jobs.
The Affordable Care Act health insurance premium tax credit fight: Most Democrats and one Republican have declined to vote for the legislation needed to keep the government open. Many of the Democrats who opposed the anti-shutdown bill brought to the Senate floor last week said they want any anti-shutdown bill passed into law to include a provision extending the current, relatively high level of ACA premium tax credit subsidies.
Congress expanded the subsidies in response to the COVID-19 pandemic. If the current rules expired, and the subsidies returned to the level in place in 2019, people with income over 400% of the federal poverty level would lose access to premium subsidies entirely. Many people with income from 300% to 400$ of the federal poverty level would see their out-of-pocket cost for the premiums increase from less than $100 per month to more than $500 per month.
ACA exchange details: HealthCare.gov and the state-based exchanges appear to be training and registering agents in the usual way and taking in plan information in the usual way, Miller said.
"The ability for enrollees to be verified and enrolled in coverage has not been impacted, and I don't anticipate it will be as a result of this current shutdown," Miller said. "The marketplace infrastructure is funded outside of federal appropriations, so core enrollment operations should continue without disruption."
Federal exchange managers recently took in plan benefits value updates. "The CMS staff who review and evaluate these filings are classified as essential employees, so they are working through the shutdown," Miller said. "The expectation is that plans will be reviewed and approved promptly."
Miller suggested that the shutdown could reduce HealthCare.gov managers' ability to promote the program and their ability to implement any new laws or regulations.
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