ACA Open Enrollment 2027 for Immigrants: Dates, Subsidies, Changes

If you buy your own insurance, open enrollment is your yearly chance to sign up or switch plans. This year the extra subsidies are gone and a 2025 law changed which immigrants get help. Current as of October 7, 2026.

When is open enrollment for 2027?

In states that use HealthCare.gov, which includes Michigan, Texas, Florida and Ohio (home to large Arab communities), the official dates are:

• November 1, 2026: first day to enroll, renew or change plans.
• December 15, 2026: last day to enroll for coverage starting January 1, 2027.
• January 15, 2027: open enrollment ends. Plans picked after December 15 start February 1.

A 2025 federal rule would have ended open enrollment on December 15 starting with the 2027 plan year. A federal court in Maryland struck that provision down on June 12, 2026, so the window still runs to January 15. The government has appealed.

State-run marketplaces can differ. Confirmed on official sites as of October 7, 2026:

What changed for 2026 and 2027?

The enhanced tax credits expired, and the 400% cliff is back

From 2021 through 2025, enhanced credits meant people under 150% of the poverty line paid close to nothing for the benchmark silver plan, and nobody paid more than 8.5% of income. They expired on December 31, 2025. The House voted to extend them on January 8, 2026, but the extension never became law, and KFF confirmed on October 6, 2026 that they have not been renewed.

So the "subsidy cliff" is back: above 400% of the poverty level you get no tax credit at all. Below it, you pay 2.15% to 10.22% of income in 2027, under the IRS table.

Full repayment of excess credits

Starting with tax year 2026, the caps on paying back excess advance credits are gone. If you underestimate income, you repay every extra dollar at tax time.

Immigrant eligibility under the 2025 reconciliation law (H.R.1)

• Since January 1, 2026: lawfully present immigrants with income under 100% of the poverty line who are barred from Medicaid because of their status can no longer get tax credits.
• From January 1, 2027: only green card holders, Cuban/Haitian entrants and COFA migrants can get tax credits. Refugees, asylees, TPS holders, trafficking survivors and people on work or student visas lose eligibility. They can still buy a plan at full price.

CMS rules and the court fights

Courts have overturned or paused most stricter provisions of CMS rules from June 2025 and May 2026, including the shorter window, the $5 charge after auto re-enrollment, and extra income and special-enrollment paperwork. CMS suspended the "failure to reconcile" rule for 2026 and 2027 on July 22, 2026. Appeals are pending, and the 2025 law adds pre-enrollment verification from 2028.

Who can buy coverage, and who can get help paying?

Citizens and lawfully present immigrants can buy plans. Financial help is what changed:

What about Medicaid and CHIP?

With low income you may qualify for Medicaid or CHIP instead; the application checks automatically. Key rules for immigrants:

• Five-year bar: most adult green card holders wait five years after getting status before full Medicaid, with some exceptions.
• Since October 1, 2026: federal funding for full Medicaid and CHIP is limited to citizens, green card holders, Cuban/Haitian entrants and COFA migrants. Refugees and asylees without a green card may lose full Medicaid unless their state pays with its own money.
• Children and pregnant women: states that chose the "lawfully residing" option (CHIPRA 214) can keep covering them with no five-year wait.
• Emergency Medicaid is still available to people who otherwise qualify.

Details in our Medicaid for immigrants guide.

Will tax credits count against me for public charge?

A new DHS rule took effect on September 18, 2026, repealing the 2022 rule that had excluded Marketplace credits and most Medicaid. It applies to green card applications filed on or after that date. DHS said it would not exempt any means-tested benefit, and that includes premium tax credits. Officers can now weigh them in the "totality of the circumstances."

• The public charge test does not apply to refugees and asylees when they adjust status, or to TPS applicants.
• People who already hold a green card generally aren't tested again, apart from special cases like long trips abroad.
• Benefits received before September 18, 2026 are judged under the 2022 rule.
• DHS says it looks at benefits the applicant received, not benefits their family members received.

If someone in your household will apply for a green card soon, talk to an immigration attorney before enrolling. See our public charge guide.

Mixed-status families: how to apply

You can apply for your U.S.-citizen children or your green-card-holder spouse even if you aren't eligible yourself. CMS guidance for assisters says non-applicants are not asked about their immigration status. Non-applicants give an SSN only if they have one, file the taxes, and request financial help. Never put an ITIN in the SSN field.

Official guidance says eligibility data isn't used for immigration enforcement, but sharing of Medicaid data with ICE has been in court since 2025. If anyone in your family is worried, talk to a lawyer or certified assister first.

Worked example: a family of four

2027 coverage uses the 2026 poverty guideline: $33,000 for a family of four in the 48 contiguous states. The table shows what the family would be expected to pay per year for the benchmark silver plan. The tax credit covers the gap between that amount and the plan's actual price in your area. Estimates only.

At $40,000, the children would usually be sent to Medicaid or CHIP, and in expansion states the adults may be too. A refugee family without green cards gets none of these credits in 2027.

How to enroll, step by step

1. Gather the basics: SSNs, a 2027 household income estimate, and details of any job-based coverage offered to you.
2. Get immigration details for each applicant: document type (green card I-551, I-94, work permit), A-Number or I-94 number, card number and expiration date. Type names exactly as printed.
3. Apply: at HealthCare.gov or your state's site, by phone at 1-800-318-2596 (TTY 711), or with a free local assister through localhelp.healthcare.gov.
4. Compare plans: check the deductible, out-of-pocket maximum and network, not just the premium.
5. Pick a plan by December 15 (December 31 in California) for a January 1 start, and pay your first premium to the insurer.
6. Upload documents if asked before the deadline, or you can lose your credits.

Common mistakes

• Letting auto-renewal run: if your status no longer qualifies for credits in 2027, your January bill could jump. Log in and update.
• Lowballing income: with no repayment cap, every extra dollar comes back at tax time.
• Skipping your tax return: if you got credits, file with Form 8962, even while the penalty is suspended.
• Paying a "broker" on WhatsApp: official enrollment and help are free.
• Ignoring tax-advantaged accounts: a high-deductible bronze plan may let you open an HSA.

What next?

Put November 1 and December 15 on your calendar, and check each family member against the table above. If you're a refugee or asylee, plan your green card application as early as the rules allow. If coverage is out of reach, see health insurance in the USA guide, such as job-based plans, community health centers and state programs. We will update this guide as the courts rule.

Frequently asked questions

Official sources we reviewed

• HealthCare.gov — Dates and deadlines for 2027 health insurance ↗
• HealthCare.gov — Coverage for lawfully present immigrants (2027 changes) ↗
• IRS — Rev. Proc. 2026-26: 2027 applicable percentage table ↗
• HHS ASPE — 2026 poverty guidelines ↗
• CMS — SHO #26-001: Section 71109 Medicaid/CHIP eligibility for noncitizens (Apr 8, 2026) ↗
• Federal Register — Public Charge Ground of Inadmissibility, final rule (Jul 20, 2026) ↗
• Covered California — Enrollment dates and deadlines ↗
• KFF — Midterm Election Update: The ACA Marketplaces (Oct 6, 2026) ↗