Most broker open enrollment checklists are built to get you through a stressful October. I’d argue October is too late to lower the stress. September is the last stretch where you can still change the outcome of a January 1 renewal, because once October arrives you’re executing whatever your client already decided.
Four things are worth finishing before October 1: sort your book by renewal risk, put conservative 2027 numbers in front of anyone weighing a move, clear the October 3 ICHRA notice deadline, and write the employee communication plan while you still have room to think about the wording.
None of the four are complicated, and every week you give yourself makes them easier.
What are the 2027 open enrollment dates brokers need to work around?
They’re settled now, after a year of not being. Open enrollment for 2027 coverage runs November 1 through January 15 on HealthCare.gov and in most state exchanges. December 15 remains the deadline to select a plan with a January 1 effective date everywhere.
| Date | What happens |
|---|---|
| October 3, 2026 | ICHRA notice deadline for a January 1, 2027 plan year |
| November 1, 2026 | Open enrollment opens in most states. Idaho opens October 15; Connecticut and Massachusetts open October 23 |
| December 15, 2026 | Plan selection deadline for January 1 coverage in every state, and the close date in Idaho |
| January 15, 2027 | Confirmed close date on HealthCare.gov and in most state exchanges |
Worth knowing how this landed, because plenty of broker-facing content still has the old answer. The CMS Marketplace Integrity and Affordability rule would have cut the federal window to six and a half weeks, down from ten and a half. A judge vacated that provision in June and HHS appealed in July. Then in early August, CMS confirmed that HealthCare.gov will run November 1 through January 15 for 2027. Oral arguments are scheduled for late October, so the window genuinely at risk is the one you’ll plan around next fall. Confirm your state exchange dates either way before you put a timeline in writing for a client.
Sort your book by who is going to shop
Pull your January renewals and put every client in one of three buckets: 1) clients who’ll absorb the increase, 2) clients who’ll complain and stay, and 3) clients who’ll shop.
The third bucket is the only one where a September conversation and a November conversation produce different outcomes.
The pressure behind that third bucket is well documented. Aon projected on August 20 that employer health costs will rise 9.5% in 2027, pushing average cost above $19,000 per employee and marking a fourth consecutive year approaching double digits. Mercer’s survey for next year found that 48% of employers with 500 or more employees expect plan changes that raise employee out-of-pocket costs, and 31% already offer or plan to offer at least one non-traditional medical plan in 2027.
When roughly a third of large employers are already looking at something other than a standard group plan, your client will probably be grateful you brought options to the table. The brokers I watch struggle are the ones who assume the renewal number has to come first and the alternatives second.
How do you quote 2027 before individual market rates are final?
You model conservatively instead of waiting. When a carrier files a requested rate range, price toward the high end of what they asked for. Show the client a cautious 2027 number now, then revise down once rates finalize. A client who budgets against the worst case and gets better news trusts the next number you hand them.
The direction of travel is already clear. KFF’s updated analysis of 276 insurers across all 50 states and the District of Columbia puts the median proposed 2027 increase at 15%, a second consecutive year of double digit hikes, with 63% of proposed changes landing between 10% and 25%. Final rates arrive in late summer and early fall, which lands after most brokers have already had the hard conversation.
We’ve been running projected 2027 proposals since August using that conservative approach. A client who sees a ballpark number in September has time to make a real decision. A client who sees the first number in November is choosing between two bad options under deadline pressure.
Lock the compliance dates
One naming note on these deadlines: the federal notice requirement now technically applies to what CMS calls the CHOICE Arrangement. Same notice, same deadline, same Department of Labor model language. If your notice template still says “ICHRA,” that’s fine; both terms are accurate right now.
- October 3 is the ICHRA notice deadline. For a January 1, 2027 plan year, the notice has to reach every eligible employee at least 90 days before the plan year starts. The Department of Labor publishes a model notice you can work from. Employees who become eligible mid-year receive their notice no later than the date coverage can begin.
- The 2027 affordability percentage is 10.22%. Up from 9.96%, and the highest the percentage has been since the ACA took effect. For plan years starting January through June 2027, the federal poverty line safe harbor works out to $135.92 per month for self-only coverage.
- ICHRA affordability moves with the market. The calculation runs off the lowest cost silver plan in the employee’s rating area minus the allowance, so every rate change shifts the math on an allowance you set months ago.
The higher percentage gives you a little more room on the allowance. Brokers who recalculate in September can use that room. Brokers who recalculate in December are confirming a number somebody already committed to.
Why the employee communication plan can’t wait until November
The decisions your employees are making are getting harder. The HRA Council’s Volume 5 report, released August 12, found that more than 20,000 US businesses now offer an ICHRA or QSEHRA, extending health benefits to at least 500,000 employees. Applicable large employers are the fastest growing segment and more than doubled on average from the prior year. ICHRA covered lives alone passed 500,000 at the start of 2026.
The same report looked at how employees behave once they have an allowance. More than half of enrollments come from workers under 45, most choose silver or gold plans, and some add more than $100 a month of their own money to buy richer coverage than the allowance alone would fund.
That’s a workforce making an active purchase decision, and the group enrollment playbook was never built to support that process. A benefits guide and a marketplace link is not a communication plan. What works is real decision support, a licensed person an employee can call, and messaging drafted before the November crush rather than during.
What if a client is already out of runway?
Call the carrier and negotiate a short term renewal. Buy three or six months, then implement properly for April 1 or July 1 instead of forcing a rushed January 1.
In my experience this works more often than brokers expect, and carriers are more willing to have the conversation than most people assume. I would rather buy a client a few months than watch a rushed implementation land badly in January. The February calls I get about a rollout that went sideways are much harder to fix than the October calls I get about a bad renewal.
Frequently asked questions
Have the 2027 open enrollment dates changed?
Not for 2027. A 2025 CMS rule would have shortened the federal window to November 1 through December 15, a judge vacated that provision in June 2026, and CMS confirmed in August that HealthCare.gov will run November 1 through January 15. December 15 remains the deadline for January 1 coverage.
What is the ICHRA notice deadline for a January 1, 2027 plan year?
October 3, 2026. The ICHRA notice has to reach every eligible employee at least 90 days before the plan year begins. Employees who become eligible mid-year receive the notice no later than the date their coverage can start. The Department of Labor publishes a model notice employers can adapt.
Can you quote ICHRA before 2027 rates are final?
Yes, using projected rates. Carriers file requested rate ranges months before regulators finalize anything, so a conservative projection priced toward the high end of the request gives a client a workable planning number in September. Revise the proposal once final rates publish in the fall.
What is the 2027 ACA affordability percentage?
10.22% of household income, up from 9.96% in 2026 and the highest the percentage has been since the ACA took effect. For plan years beginning January through June 2027, an employer meets the federal poverty line safe harbor by keeping self-only coverage at or under $135.92 per month.
How late is too late to move a client to ICHRA for January 1?
Once you pass the October 3 notice deadline, a January 1 start becomes difficult and a clean one becomes unlikely. At that point the better play is usually a short term renewal with the current carrier and a properly staged implementation for April 1 or July 1.
Ready to pressure test a timeline?
If you have a client heading toward a bad January renewal and you’re not sure whether a January 1 move is realistic, send us the census. We’ll give you a straight answer about fit and timing, including the times the honest answer is that the timeline doesn’t work.
Sources
- Aon, US employer health care costs projected to rise 9.5% in 2027 (August 20, 2026)
- KFF, How much and why ACA Marketplace premiums are going up in 2027 (updated August 3, 2026)
- HRA Council, Growth Trends for ICHRA and QSEHRA, Volume 5 (August 12, 2026)
- Mercer, Survey on Health and Benefit Strategies for 2027
- Mercer, 2027 affordability percentage for employer health coverage increases (IRS Rev. Proc. 2026-26)
- CMS, 2025 Marketplace Integrity and Affordability Rule overview
- US Department of Labor, Individual Coverage HRA Model Notice
- CMS, Statement Regarding City of Columbus v. Kennedy (August 4, 2026)
- healthinsurance.org, ACA open enrollment deadlines by state (updated August 10, 2026)
Ready to talk through ICHRA opportunities for your book of business? Let’s connect.
— Andy Stein, Founder & President, The Worksite Group
