HealthCare.gov opens 2027 enrollment with a Jan. 15 deadline; state dates vary and an appeal is pending

Open enrollment for 2027 health plans on HealthCare.gov began Sunday, Nov. 1, and runs through Friday, Jan. 15, the Centers for Medicare & Medicaid Services said in an Oct. 30 fact sheet.¹ HealthCare.gov’s guide says people must enroll by Dec. 15 for coverage starting Jan. 1. Enrolling after that, by Jan. 15, means coverage starts Feb. 1.² Those dates do not apply in every state.

State deadlines differ

For 2026, 30 states used HealthCare.gov; 20 states and the District of Columbia ran their own exchanges.³ Other dates include:

• California: Nov. 1 to Jan. 31, with a Dec. 31 deadline for a Jan. 1 start.⁴
• Massachusetts: Oct. 23 to Jan. 23, with a Dec. 23 deadline for a Jan. 1 start.⁵
• Idaho: Oct. 15 to Dec. 15, for coverage starting Jan. 1.⁶

The ruling behind the date is on appeal

U.S. District Judge Brendan A. Hurson of Maryland on June 12 vacated a provision of a 2025 CMS rule that, starting in 2027, would have required enrollment periods to end no later than Dec. 31. He called shortening the period “arbitrary and capricious.” His order also vacated a $5 charge on automatic re-enrollees.⁷⁸

The government appealed July 16.⁹ A panel of the 4th U.S. Circuit Court of Appeals heard arguments Friday, Oct. 30.¹⁰ The government asked for a decision by Dec. 31.¹¹ Its brief says the judgment “should be reversed” and that HHS concluded a shorter period “would strike a better balance.”¹² The plaintiffs argued in district court that CMS “ignored a wealth of evidence” favoring January enrollment.⁷

Neither docket shows a request to put the June ruling on hold during the appeal.¹³¹⁴ The same brief lists vacated provisions HHS “will not enforce” absent further rulemaking. The $5 charge is on that list; the open enrollment provision is not.¹²⁸

Premiums and tax credits

CMS says more than 75% of HealthCare.gov purchasers “will continue to have access to premiums at or below $50 in 2027.”¹ KFF, in an Oct. 30 analysis, put the average increase in finalized benchmark silver premiums for 2027 at 13%.¹⁵

KFF reports enhanced premium subsidies have expired and that people with incomes above 400% of the federal poverty level no longer qualify for premium tax credits.¹⁵ The House voted 230-196 on Jan. 8 to pass H.R. 1834,¹⁶ described by the American Hospital Association as a three-year extension.¹⁷

The 2027 payment notice

CMS finalized its 2027 payment notice May 15. “American taxpayers deserve to know their dollars are going only to people who truly qualify,” CMS Administrator Mehmet Oz said.¹⁸¹⁹ On July 16, Hurson stayed eight parts pending a final ruling on the merits:²⁰

• Failure-to-reconcile policy
• Income verification for low-income enrollees
• Revocation of income attestation
• Special enrollment verification
• Expanded out-of-pocket limits
• Expanded catastrophic plan eligibility
• Network adequacy changes
• Elimination of standardized plan requirements

His opinion says the plaintiffs argue the provisions steer people to less generous coverage and the government says they help enrollees avoid unexpected costs.²¹ CMS said Aug. 4 that exchanges cannot operate a failure-to-reconcile policy in plan year 2027.²² Docket entries through Oct. 13 show no appeal of the stay.²³

HealthCare.gov says starting Jan. 1, 2027, only people with certain immigration statuses qualify for savings.²

What the records do not show

• No record opened says what would happen to the 2027 window if the appeals court reversed during enrollment.
• Docket copies available Nov. 1 end Oct. 23 at the 4th Circuit and July 21 in the 2025 case, so later filings may be missing. No appellate ruling was found.¹³¹⁴
• CMS’s fact sheet does not say whether its $50 figure is after tax credits and does not mention the expired credits.¹
• California’s page names no plan year.⁴
• Senate action on H.R. 1834 could not be confirmed.
• Other state exchanges’ dates were not checked individually.