The Centers for Medicare & Medicaid Services (CMS) issued its 2027 Payment Notice final rule on May 15th. It runs to hundreds of pages, covers the ACA marketplace for plan year 2027, and affects anyone who buys health insurance through HealthCare.gov or a state-based exchange.

That includes a lot of small business owners and the self-employed - the 33 million Americans who don't get insurance through an employer and have to navigate the individual market on their own.

Here's what's actually in it, translated.

Lower user fees - and what that means for your premium

The ACA Exchanges charge insurers a fee to participate in the marketplace. Those fees get passed on in the form of higher premiums.

In 2026, that fee was 2.5% for the federal exchange (HealthCare.gov) and 2.0% for state exchanges using the federal platform. Under the new rule, those drop to 1.9% and 1.5% respectively starting in 2027.

That's not a massive number, but on a $500/month individual premium, a 0.5-0.6 percentage point reduction translates to roughly $3-4/month in downward pressure. Across a year, it's $36-48. Not life-changing, but directionally the right move.

CMS says the goal is to "put downward pressure on premiums" and expand access to affordable coverage. The fee reduction is the most straightforward mechanism for doing that.

Tighter eligibility checks - what it means if you got a subsidy

The rule reinstates pre-enrollment verification for Special Enrollment Periods (SEPs). Under previous rules, many people could self-attest that they qualified for a special enrollment window (job loss, new baby, etc.) and enroll immediately. Under the new rule, you'll need to document that qualifying event before your coverage kicks in.

It also aligns subsidy eligibility with the recently passed Working Families Tax Cut legislation, which means some income thresholds and subsidy calculations will shift.

The practical effect: if you've been getting a premium tax credit (the ACA subsidy) based on estimated income, expect more scrutiny at enrollment. Keep documentation of your income handy - especially important for self-employed people whose income fluctuates year to year.

The rule also tightens oversight of insurance agents and brokers, including new requirements around documenting consumer consent. This comes after a wave of unauthorized plan switches - cases where brokers enrolled consumers in new plans without their knowledge to capture commissions.

More plan options - including cheaper catastrophic coverage

This one is actually good news for the self-employed.

The rule removes the requirement for insurers on HealthCare.gov to offer standardized plan options. That sounds technical, but what it means is that insurers now have more flexibility to design creative plans - potentially with lower premiums, higher deductibles, or different network structures than the standard bronze/silver/gold tiers.

It also expands access to catastrophic plans:

• Insurers can now offer catastrophic plans with terms up to 10 consecutive plan years (previously, these were annual)
• More people qualify for catastrophic coverage through expanded hardship exemptions

Catastrophic plans have very low premiums but very high deductibles - usually over $9,000. They make sense if you're young and healthy, primarily want protection against a major medical event, and can cover routine care out of pocket. For a 28-year-old freelancer who rarely sees a doctor, this could be a real money-saver.

What states are getting more control over

The rule gives states that use the federal platform more flexibility to run their own certification reviews - essentially, their own checks on whether plans meet local market standards.

For most small business owners, this won't matter much in 2027. But in the longer run, it means the marketplace in your state could look meaningfully different from the marketplace in another state. Plans, networks, and available insurers will diverge more over time.

What this doesn't change

A few things worth noting:

Open enrollment timing is unchanged. You still enroll in ACA marketplace plans during open enrollment (typically November 1 to January 15) or during a qualifying special enrollment period.

The subsidy cliff is still there. If your income exceeds 400% of the federal poverty level, you pay full premium - no subsidy. The rule doesn't change that structure, though it aligns with existing tax cut legislation.

The penalty for not having insurance remains $0 federally. Some states (California, Massachusetts, New Jersey, etc.) have their own penalties.

The bottom line for small business owners

If you're self-employed or shop for individual coverage: watch for more plan options in 2027, and expect to document your income more carefully when enrolling. The lower user fees should provide modest premium relief.

If you offer coverage to employees through the small group market: this rule primarily affects the individual ACA exchanges, not SHOP (Small Business Health Options Program) plans. Check with your broker for SHOP-specific changes.

The rule takes effect for plan year 2027, which means the plans you'll see during open enrollment in fall 2026.

Source: CMS 2027 Payment Notice Final Rule - published May 15, 2026