The Centers for Medicare & Medicaid Services (CMS) has announced two major updates that will directly impact hospitals, patients, and the revenue cycle in the coming years:

  1. Open Enrollment Period (OEP) Adjustments
  2. Expanded Access to Catastrophic Coverage

Both changes are designed to respond to rising premiums and shifting coverage dynamics in the individual market.

Open Enrollment Timing

  • Plan Year 2026: Open Enrollment will run November 1, 2025 – January 15, 2026 (10.5 weeks).
  • Plan Year 2027 and Beyond: Open Enrollment will be shortened to November 1 – December 15 (6.5 weeks).
  • New Standard:
    • All Exchanges must begin no later than November 1.
    • All Exchanges must end no later than December 31.
    • The OEP cannot exceed 9 weeks.
  • Coverage Start Date: All enrollments during OEP will be effective January 1.

Why this matters: Shorter enrollment windows increase the risk that eligible patients will miss deadlines, leaving hospitals with more uninsured or self-pay patients unless proactive outreach and education are in place.

Rising Premiums, New Coverage Paths

Premiums in the individual market are projected to rise sharply for 2026, creating affordability challenges for patients just outside subsidy thresholds, earning “too much” to qualify for premium assistance but not enough to pay full premiums comfortably.

To help, CMS is expanding access to catastrophic health plans through a streamlined hardship exemption process, effective November 1, 2025.

What’s Changing for Patients

  • More eligible consumers: Catastrophic plans will extend beyond young adults and narrow hardship cases to those ineligible for subsidies, either too far above or below the federal poverty line.
  • Simpler enrollment: HealthCare.gov will automatically flag hardship eligibility during applications, and paper forms are being streamlined.
  • What catastrophic coverage includes:
    • Lower monthly premiums
    • All ACA essential health benefits
    • Three primary care visits before the deductible
    • Preventive services at no cost
    • Financial protection against major illness or injury

Why This Matters for Hospitals

  • Partial win: Catastrophic plans can keep patients from being entirely uninsured, but high deductibles still leave many with balances they cannot pay.
  • Self-pay remains a concern: Hospitals will continue to see rising uncompensated care unless patients are carefully guided toward the right coverage option.
  • Community impact: Even imperfect coverage is better than none. Catastrophic plans may encourage patients to engage in preventive and primary care, rather than waiting until an ER visit becomes unavoidable.

RCA’s Role in the Transition

For more than 30 years, RCA has partnered with hospitals to adapt to policy shifts like this. Our role is to:

  • Screen and guide patients through Medicaid, CHIP, catastrophic coverage, or charity care.
  • Protect hospital revenue by converting uninsured accounts into covered accounts and safeguarding DSH and reimbursement streams.
  • Humanize the process with compassion and professionalism, ensuring patients feel supported while hospitals maintain financial stability.

Bottom Line

Between shorter open enrollment windows and rising premiums, the next two plan years will reshape how patients access coverage. Catastrophic plans will be a lifeline for some, but not a perfect solution.

With RCA by your side, your hospital can help patients navigate these changes, secure the coverage they qualify for, and reduce the risk of self-pay balances that strain your bottom line.