A note from OCI Executive Vice President Nate Olson:

As we head into ACA renewal season, many agents are hesitating to enroll their clients waiting to see whether Congress will extend the expanded Advanced Premium Tax Credits (APTC). While it’s understandable to want clarity before locking clients into 2026 plans, this delay is unnecessary for the vast majority of consumers and may put both agents and clients in a last-minute scramble. Here’s what you need to know and what you should communicate to your clients right now.

1. The Possible APTC Extension Only Affects a Small Slice of Consumers

There’s been a lot of conversation about whether Congress will extend the enhanced subsidies introduced under the American Rescue Plan. But if extended, these enhancements only impact households above 400% of the Federal Poverty Level (FPL). For clients under 400% FPL, nothing changes. Their subsidies are calculated the same way and are not dependent on whether the expanded credits are renewed.

2. If Your 2026 Quote Shows a Subsidy, That Subsidy Will Not Change

If you’re running 2026 rates and the system shows your client is subsidy-eligible, that subsidy amount will NOT change based on Congressional action.

Why? Because expanded APTCs only affect those who wouldn’t have qualified at all under prior rules. If your client is already receiving a subsidy under the standard formula, the expanded credits do not increase or decrease it. So if your quote shows a PTC today, you’re safe to move forward.

3. Waiting Creates Unnecessary Risk for You and Your Clients

Delaying enrollments until Congress acts, or doesn’t act, increases the chances of missing the OEP deadline and puts more pressure on your internal processes. Agents already face heavy Q4 workloads and waiting compresses timelines and increases the risk of mistakes. Postponing your renewals forces both new and existing business into the same high-pressure timeframe creates an unnecessary strain on you and your clients.

Here’s the simple message: If your client qualifies for subsidies today, enroll them.

Your clients depend on you to keep their coverage stable. Don’t let a hypothetical policy change create an unnecessary bottleneck.