For most of the past five years, the ACA marketplace functioned as a parallel coverage track for workers who were self-employed, between jobs, or employed by small businesses without group coverage. That track effectively absorbed a segment of the workforce that might otherwise have pressed employers for benefits. When enhanced premium tax credits expired at the end of 2025, the parallel track closed and the pressure redirected.
The Urban Institute and Commonwealth Fund estimated that 4.8 million people would lose coverage outright when the subsidies lapsed.The same analysis projected that roughly 3.2 million people would shift toward employer-sponsored coverage as individual market premiums became unaffordable, a pre-expiration model estimate given that realized 2026 employer enrollment data is not yet publicly available.
Average out-of-pocket premiums rose 114 percent for subsidized marketplace enrollees in 2026, according to KFF data, with average deductibles increasing by roughly $1,000 per person as workers who stayed downgraded to higher-deductible bronze plans.
That shift has arrived at employer health plans and at the brokers advising them, not as a headline but as a change in what employees are bringing to open enrollment conversations.
For much of the enhanced-subsidy era, many self-employed, gig, and part-time workers at smaller employers could access affordable individual coverage without involving their employer at all. That independence ended with the subsidies. Ogletree Deakins, the labor and employment law firm, noted in a December 2025 analysis that employee demand for employer-sponsored health benefits was likely to surge in 2026 as individual market premiums became harder to absorb.
The practical consequence is that HR teams at smaller employers are fielding coverage questions from workers who previously handled their own insurance. Those workers arrive with limited familiarity with group plan structures, cost-sharing mechanics, and network restrictions. They are also arriving under deadline pressure: open enrollment for 2027 coverage begins November 1, and the federal marketplace deadline is now December 15, a 45-day window rather than the previous 75.
The CBO projected individual market premiums would rise a further 7.7 percent in 2027 on top of 2026 increases. Workers newly reliant on employer coverage have no reason to expect stability from the market they just left.
The enrollment pressure falls first on HR, but brokers shape how well HR is prepared for it. An employer that has not updated its open enrollment materials to address subsidy expiration is presenting 2024 communications to a 2026 workforce, one that includes people who watched their marketplace costs double and are now making unfamiliar decisions about group plan options.
The communication gap matters more than it might appear. When employees do not understand why their coverage changed or what their options mean in practice, they attribute the confusion to the employer rather than to the policy environment. Brokers who help clients address that friction before November, with plain-language explanations of what changed in the marketplace and what the cost-sharing tradeoffs are for the available group options, are doing work a competing quote cannot replicate.
The same disruption that increased employer communication work also expanded the pool of workers who need broker-assisted coverage guidance. Workers who previously bought individual coverage independently and are now evaluating group plans for the first time are not well positioned to compare options without help. Brokers who reach small and mid-market employer clients before enrollment opens have an opening to add decision-support resources that were not necessary in prior years.
The CBO's 7.7 percent projected premium increase for 2027 in the individual market also means this is not a one-cycle adjustment. Workers who moved from marketplace coverage to employer-sponsored plans in 2026 are unlikely to find the individual market more affordable next year. The communication and decision-support work brokers take on this enrollment season will need to be built into how those employer clients approach benefits going forward, rather than treated as a response to an unusual year.
