ACA 101: Selling Under-65 Health Insurance

Looking to expand your insurance business into the under-65 health insurance marketplace?

We’re covering the ins and outs of the Affordable Care Act (ACA) and selling under-65 health plans. Here’s what you need to know!

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What Is the Affordable Care Act (ACA)?

The ACA is a federal law, signed in 2010, that reformed America’s health care and insurance landscape. Formally known as the “Patient Protection and Affordable Care Act” and colloquially called “Obamacare,” the ACA includes several key provisions that gave 24.2 million Americans affordable health coverage during the 2025 Marketplace Open Enrollment Period (OEP).

Key provisions:

• The creation of health insurance marketplaces, or exchanges
• The individual mandate — which required every American to have health insurance or pay a tax penalty
• People with pre-existing conditions cannot be denied coverage or charged more for it
• Children can stay on a parent’s plan until they turn 26 years old
• Preventative care at no additional cost
• Subsidies, or tax credits, for qualifying individuals/families purchasing through the marketplace
• The expansion of Medicaid for low-income adults up to 138 percent of the Federal Poverty Level

The individual mandate penalty was repealed at the federal level in 2019. A select number of states have since implemented their own health insurance individual mandates and penalties, including:

• California
• The District of Columbia
• Massachusetts
• New Jersey
• Rhode Island
• Vermont (has their own individual mandate, but they do not have a penalty associated with it)

May Only Require One Certification (at No Cost!)

If you sell Medicare Advantage and Part D prescription drug plans, you’ll be familiar with Medicare FWA training (a federal requirement) and carrier certifications.

To sell under-65 health plans on HealthCare.gov, insurance agents must only complete one federal certification — the Federally Facilitated Marketplace (FFM) certification.

Carrier certifications aren’t required and FFM certification is completely free.

If agents are selling in a state-based marketplace (SBM), they may only have to complete that state’s ACA certification.

ACA Plans Will Complement Your Current Insurance Portfolio

If you’re already selling other insurance products, like Medicare plans, why not add under-65 health plans to your portfolio? You most likely work with clients who are under 65 or who have spouses or kids who are under 65 who need health insurance help.

When you add ACA health plans to offerings, you can better serve your current clients and any referrals that come your way while growing your commissions!

Establish a Medicare Sales Pipeline

Your under-65 clients could eventually become leads for your Medicare business or the other products you sell!

We recommend that agents grow their businesses and foster lifelong relationships with their clients by developing a Medicare pipeline.

When your clients with an ACA policy turn 65, they’ll likely turn to you for continued insurance assistance. As their trusted agent of record, you could find a great Medicare policy that fits their health care needs.

Understanding the ACA Marketplace & Exchanges

If you’re going to start selling under-65 health plans, you need to know about the ACA marketplace and exchanges. Keep reading for the details!

What Is the ACA Marketplace?

The ACA marketplace, also known as the federal health insurance marketplace or exchange, is a website called Healthcare.gov where Americans can go to buy under-65 health insurance plans. Every state that participates in the federal marketplace will conduct ACA sales and other marketplace functions through this platform.

Some states have their own marketplace websites, or exchanges, known as SBMs. These are independently operated marketplaces that conduct the same functions as the federal marketplace separately.

On-Exchange vs. Off-Exchange Plans

ACA health plans are available on the exchange (on-exchange) or off the exchange (off-exchange). Plans available on the exchange include those bought through HealthCare.gov (the federal marketplace), those bought on a state’s exchange website, or those bought through an approved exchange enrollment platform, like HealthSherpa. Off-exchange plans are those bought directly from the carrier.

On-exchange plans must provide essential health benefits and follow specific guidelines set by the ACA. Only on-exchange plans can accept ACA subsidies!

Individuals cannot use an ACA subsidy to buy an off-exchange plan.

Off-exchange plans usually offer most, if not all, the essential health benefits as their on-exchange counterparts. However, individuals cannot use an ACA subsidy to buy an off-exchange plan.

The Open Enrollment Period & New SEPs

Every year, people can shop for and enroll in new under-65 health plans on the marketplace during the Open Enrollment Period (OEP), which runs from November 1 to January 15 in most states, or during a Special Enrollment Period (SEP).

Your client may have an SEP if they’ve recently experienced any of the following:

• Job loss
• Moving to a new zip code
• New child or death in the family
• Coverage loss
• Marriage/divorce
• Citizenship status change
• Government error
• Change in subsidy eligibility
• Qualifying federal reason
• Losing job-based coverage, Medicaid, eligibility for Medicare, or coverage through a family member

To take advantage of an SEP, you and your clients must act within 60 days of the qualifying life event.

ACA Subsidies & Their Eligibility Requirements

You may have heard a lot about ACA subsidies lately. What are ACA subsidies, and how do people qualify for them?

ACA subsidies are an Advanced Premium Tax Credit (APTC) designed to help lower-income and middle-income individuals and families afford health insurance. To qualify, someone must meet the following criteria:

• Income is between 100 percent to 400 percent of the Federal Poverty Level
• Buying health plan through the marketplace or exchange
• Does not have “affordable” employer-sponsored coverage available to select*

*Family members can access subsidized ACA coverage if an employee’s cost for their coverage exceeds 8.39 percent of the household’s income. This is thanks to the closing of the family glitch. All family members will now be taken into consideration in the eligibility calculations, not just the employee.

To estimate 2026 subsidies, use the 2025 income levels to calculate savings.

Note: Individuals who fall below 138 percent of the FPL (or their state’s designated limit) may qualify for free-or-low-cost health insurance through Medicaid. If your client lives in Hawaii or Alaska, please be aware that poverty guidelines differ. You can review those states’ guidelines on HHS.gov.

When helping your client apply for a plan, you’ll work together to estimate how much income they think they’ll have for the following year. Then, they’ll receive a subsidy based on that income estimate, as well as additional factors. When your client files their taxes at the end of the year, they may have to pay back some or all of the subsidy if they earned over their estimated income for the year. Alternatively, if they made less than their original estimate, they should get a refund of any additional portion of the subsidy they may qualify for.

Check out our Ritter blog post debunking some of the myths that surround the ACA, including income requirements!

Bronze, Silver, Gold, Platinum ACA Metal Levels Explained

Under-65 marketplace plans are categorized into four metal tiers: Bronze, Silver, Gold, and Platinum. Basically, these tiers can tell you and your clients how covered medical costs are shared between the policy and the policyholder (but not the level of care or the plan’s covered services).

These tiers can tell you and your clients how covered medical costs are shared between the policy and the policyholder.

As you can see from the table, as the metal tiers go up, the member’s coinsurance responsibility goes down while the plan’s coinsurance responsibility goes up. The most prevalent tier in the marketplace is the Silver tier due to the ability to apply subsidies. We recommend suggesting a Silver plan to a client that qualifies for subsidies.

Consider your client’s budget and what makes sense for them. Some clients may find a Bronze plan paired with another plan such as a hospital indemnity plan to be more affordable and offer the coverage they are looking for.

Catastrophic Health Plans

In addition to the metal tiers, there are also catastrophic health plans available for specific circumstances. These plans typically have low monthly premiums and very high deductibles and are more for clients looking for an affordable route to protect themselves from worst-case scenarios (e.g. serious illnesses or injuries).

Your client must fall under specific criteria to qualify for this plan, such as those who:

• Are under 30
• Qualify for a hardship exemption or affordability exemption (based on Marketplace or job-based insurance being unaffordable)

This type of plan covers the same 10 essential health benefits as other Marketplace plans do, including preventive services at no cost. Along with that, they also cover at least three primary care visits per year before the deductible is met.

Recent Exceptions

CMS announced on September 4, 2025, that they have issued new guidance for circumstances that fall under the hardship exemption policy for Plan Year 2026. The issue addresses rising health insurance premiums by expanding access to more affordable catastrophic options. Hardship exemptions are also available for individuals who are ineligible for premium subsidies or cost share reductions.

Requirements for Agents Selling ACA Plans

Before you can sell ACA plans, you must fulfill a few requirements, such as completing licensing, certification, and appointments.

When you’re working with consumers, you must also collect consumer authorization and eligibility attestations.

Note: The 2025 Marketplace Integrity and Affordability Final Rule finalizes additional safeguards to protect consumers from improper enrollments and changes to their health care coverage. It also establishes standards to ensure the integrity of ACA exchanges.

The Agent Advantage

You may know that navigators are also available to help individuals find and enroll in on-exchange plans. However, there’s a big difference between navigators and agents or brokers like you: Navigators cannot recommend one plan over another.

Health insurance marketplace navigators cannot recommend one plan over another — but you can!

You can help your clients understand the best plans for them based on their needs. By getting involved in this market, you’re looking out for the best interest of your clients, and yours as well! Under-65 sales can increase your bottom line and keep your book of business booming for years to come as the market still remains strong!

Still feeling uneasy about selling ACA Marketplace products? Check out our comprehensive agent eBook, The Complete Guide to Selling Affordable Care Act Insurance Plans to boost your confidence and get started!

The ACA health market has seen a lot of changes within the past few years. Here at Ritter, we’re embracing the sales opportunities that the ACA presents. We’re excited to see your business grow with under-65 sales!

Interested in learning more about Ritter’s under-65 health contracting opportunities? Contact your Sales team.