This Open Enrollment Is Practice for What’s Coming in 2027
The rules that are about to change carry real consequences for clients who don’t act. This year is lower stakes, which makes it the right year to find your gaps.
Open enrollment this year runs November 1 through January 15, though getting enrollments done by December 15 still matters for a January 1 effective date. That’s the immediate deadline in front of you. But Jordyne Cerullo, Senior Director of Agency Sales at HealthSherpa, flagged something bigger coming next year during her conversation with Mike Papuc, The Brokerage Inc.’s National Health Sales Director: starting in 2027, coverage won’t renew on its own anymore.
What “Passive Renewal” Means, and What’s Changing
Right now, if a client does nothing, their marketplace coverage typically continues automatically into the next plan year. That’s the system agents and clients are used to. Starting August 1, 2027, that changes. Clients will need to actively renew their coverage, meaning they’ll need to take a real step to confirm it rather than letting it carry over.
Papuc laid out what happens if a client doesn’t take that step: a policy that isn’t actively renewed gets termed by CMS, which means the coverage ends. The last day that client would have coverage is December 31, 2027, right as the 2028 plan year begins. A client who assumes their coverage just continues on its own, the way it does today, could lose it entirely once this rule takes effect.
Why This Year’s Open Enrollment Matters for Next Year
The work required to avoid that outcome, actually reaching every client in your book and confirming they’ve taken action, is the same work that matters during a normal open enrollment too. A client you can’t reach this year misses a deadline, a problem, but a recoverable one. Starting in 2027, that same client could lose their coverage completely if they don’t actively renew. The process is identical either way. Only the consequence changes.
Use This Year as Your Test Run
Cerullo’s advice is to treat this open enrollment as a chance to find out, now, whether you’re ready for what 2027 requires. Two honest questions worth asking yourself: if you needed to contact every client in your book this month, could you reach all of them? And do you realistically have the time to work through that entire list, or would some clients fall through the cracks?
If the honest answer to either question is no, this is the year to fix it, while a gap in your process costs a missed deadline instead of a client’s coverage.
Where to Start
Cerullo pointed specifically to the renewals tab already built into HealthSherpa. Her advice: use that functionality now, and treat this open enrollment as practice for the habits you’ll need once more is on the line. Build a reliable way to reach your whole book this year, and you’ll walk into 2027 with a process that already works instead of building one from scratch under pressure.
Preparation is what decides how this open enrollment goes, and it’s what will decide whether your clients still have coverage heading into 2028. The Brokerage Inc. has been through fifty years of industry change alongside agents like you, and this one is no different.
This closes out the three-part HealthSherpa series. Part one covered Agent Authorization, launching October 12, part two covered Identity Verification.
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