Open Enrollment 2027 Is Shorter: An ICHRA Employer Guide

When does open enrollment for 2027 actually start and end?

On HealthCare.gov, the federal marketplace platform used by 27 states, open enrollment for coverage starting January 1, 2027 runs from November 1 through December 15, 2026 (CMS.gov, "2025 Marketplace Integrity and Affordability Final Rule" fact sheet, fetched this week; federal, applies to the 27 states on the federal platform). That is a 45-day window. For the five plan years before it, 2022 through 2026, the same window ran from November 1 through January 15, a full 76 days (45 CFR 155.410(e)(4)(i), Cornell Law School Legal Information Institute, current CFR text, fetched this week; federal).

If your mental calendar still says "open enrollment runs into mid-January," that calendar is out of date for most of the country starting this cycle. The rule that changed it, 45 CFR 155.410(e)(5), applies to every state, not just the ones using HealthCare.gov, though the exact end date differs depending on which kind of Exchange your employees' state runs. The rest of this guide works through exactly what changed, which states it hits hardest, and what it means for the calendar you use to run your own ICHRA rollout.

Why the government shortened the window

The change comes from the 2025 Marketplace Integrity and Affordability Final Rule, published by the Centers for Medicare & Medicaid Services (CMS) in the Federal Register on June 25, 2025 (90 FR 27074). Among other provisions, it rewrites 45 CFR 155.410, the regulation that sets the annual open enrollment period, or OEP: the one yearly window when anyone can buy or change an individual marketplace plan without a qualifying life event, as opposed to a narrower special enrollment period available only to people with a specific triggering event.

CMS's own stated reasons, from its fact sheet on the rule: shortening the window is meant to "reduce consumer confusion," "align more closely with open enrollment dates for many employer-based health plans," "encourage continuous coverage," and "reduce the risk of adverse selection from consumers who may otherwise wait to enroll until they need health care services" (CMS.gov, 2025 Marketplace Integrity and Affordability Final Rule fact sheet, fetched this week). Whether or not you buy every piece of that reasoning, the practical effect is the same either way: employees now have roughly a month less runway to shop, decide, and enroll before coverage has to start.

One nuance worth naming directly, because trade coverage has muddied it: separate litigation, City of Columbus v. Kennedy (D. Md.), challenged several provisions of the same final rule in 2025, and some of those provisions were stayed or narrowed. The open enrollment length change was not one of them. It is fully in effect, beginning with the open enrollment period for plan year 2027, which is the window opening this coming November.

The old calendar next to the new one

Laid out side by side, the arithmetic is simple, and it is worth doing once so the number sticks. The old window: November 1 to January 15, 76 calendar days. The new federal-platform window: November 1 to December 15, 45 calendar days. That is 31 fewer days, about four and a half weeks, to research plans, compare a reimbursement amount against real premiums, and finish an application.

Source: 45 CFR § 155.410(e)(4)-(5) (Legal Information Institute, current CFR text, fetched this week); CMS.gov, 2025 Marketplace Integrity and Affordability Final Rule fact sheet, fetched this week. Federal.

Not every state has the same 2027 dates

"Open enrollment" is not one national date; it depends on what kind of Exchange your employees' state runs. There are three arrangements, per CMS's own current marketplace-type map (CMS.gov, Marketplace Types map, page last modified September 1, 2026, fetched this week):

Source: CMS.gov Marketplace Types map, page last modified 09/01/2026, fetched this week. Federal, current for plan year 2027.

A Federally-Facilitated Marketplace (FFM) state uses HealthCare.gov directly, and CMS itself sets the dates: November 1 to December 15, 2026 for plan year 2027. A State-Based Marketplace on the Federal Platform (SBM-FP), currently Arkansas and Oklahoma, still runs on HealthCare.gov's technology but retains some state-level authority over the exchange. A full State-Based Marketplace (SBM) runs its own separate website and sets its own open enrollment dates entirely, subject only to the federal floor. Twenty-one states plus DC run a full SBM, and that number has been growing: Virginia moved to a state exchange in fall 2023, Georgia in fall 2024, and Illinois in fall 2025 (CMS.gov Marketplace Types map, fetched this week).

If your workforce is entirely in one FFM state, this is close to a solved problem: the date is Dec 15, 2026, and CMS has already said so. If any part of your team lives in an SBM state, you do not get to assume the federal date applies to them, and, as the next section shows, you may not even be able to look the date up yet.

Ohio and Georgia: two states, two calendars, two economics

ICHRA Savings focuses heavily on Ohio and Georgia employers, and the two states happen to sit on opposite sides of this exact split. Ohio is an FFM state; its 2027 open enrollment date is already fixed at November 1 to December 15, 2026, set by CMS. Georgia is an SBM state, running its own exchange, Georgia Access, and its 2027 dates are not yet public.

Georgia Access ran its plan-year-2026 open enrollment from November 1, 2025 through January 15, 2026, a 76-day window (Office of the Commissioner of Insurance and Safety Fire, Georgia, press release dated October 31, 2025, fetched this week; state, Georgia). That is the same length as the old federal window, and it is now 13 days longer than the 63-day maximum that takes effect for plan year 2027. Georgia Access has to shorten its window to comply. As of September 1, 2026, the front page of georgiaaccess.gov still displays plan-year-2026 dates, with no 2027 announcement yet (georgiaaccess.gov, fetched this week; state, Georgia). Georgia announced its 2026 dates on October 31, 2025, roughly six weeks before the January cutoff that year, so a similar-timed announcement for 2027 is plausible but not guaranteed, and it is not something you should plan an employee communication calendar around before it exists.

Source: ICHRA Savings county dataset, src/data/qualified_counties.json, cross-verified against CMS public-use marketplace files. Plan year 2026. Figures are estimates, not quotes, and are not a guarantee of savings for any specific employer.

Notice these two examples cut in different directions, and it is worth being honest about that instead of only picking the flattering county. Montgomery County's estimated 58.3 percent savings is one of the stronger numbers in our entire dataset. Cobb County's estimated 11.5 percent is real, but modest, and a modest saving is a weaker reason to rush a rollout into a compressed, not-yet-published enrollment window. The exchange-type distinction in this article is about your calendar risk, not your savings potential; those are two separate questions, and Georgia's county-level economics vary widely enough that you should not assume one number for the whole state either way.

Where this collides with your ICHRA notice deadline

Your ICHRA has its own timing rule, separate from the marketplace calendar: under 26 CFR 54.9802-4, an employer generally has to give eligible employees written notice of the ICHRA's terms at least 90 days before the plan year begins, so that an employee who is eligible on day one of the plan year gets the tighter, 60-days-before version of their own enrollment window rather than the more forgiving 60-days-before-or-after version. We cover that deadline's exact math, including this year's October 3, 2026 cutoff for a January 1, 2027 plan year, in our notice deadline guide.

The two rules have always coexisted, but a shorter marketplace window changes how much slack a late notice leaves behind. Picture an employer who sends the ICHRA notice on, say, November 20, 2026, comfortably past this year's October 3 deadline. Under the old Nov 1 to Jan 15 calendar, a late notice still left employees roughly eight weeks to shop before the window closed. Under the new Nov 1 to Dec 15 calendar on the federal platform, that same late notice leaves them barely three and a half weeks, and if the notice slips further into December, some employees could run out the enrollment window entirely before they act. The compliance deadline for the notice itself has not moved. What has moved is how much a missed deadline actually costs you in practice.

Build your 2027 calendar backward from December 15

The clearest way to plan around a shorter window is to stop thinking forward from today and instead work backward from the deadline. Here is that calendar for an FFM-state employer targeting a clean January 1, 2027 ICHRA start, with Georgia Access dates to be substituted in once the state publishes them.

Illustrative rollout calendar built from 26 CFR 54.9802-4 (90-day notice) and 45 CFR 155.410(e)(5) and the CMS.gov final rule fact sheet (open enrollment dates), fetched this week. Not a guarantee of any specific employer's timeline.

Read backward like this, the sequence is not complicated, but it does compress. Under the old calendar, an employer had until roughly mid-January to still catch late enrollees. Under the new one, December 15 is a hard wall for HealthCare.gov states, and every task above it has to fit inside a genuinely tighter September-through-December stretch. If your workforce spans an SBM state like Georgia, hold this same structure but treat the enrollment-close date as a placeholder until the state actually publishes it, and build in a buffer rather than assuming it will land later than 63 days after November 1.

What missing the new window actually costs

Missing open enrollment is not a fine; it is a coverage gap, and it is worth putting a real number next to that gap instead of leaving it abstract. The 2026 national average marketplace benchmark premium, the second-lowest-cost silver plan used to calculate premium tax credits, is $625 per month before any subsidy (KFF State Health Facts, Average Monthly Marketplace Premiums by Metal Tier, published October 2025 reflecting 2026 plan-year data, fetched this week; national average). Georgia's own state average sits at $615 per month and Ohio's at $513 per month on the same measure (same source).

An employee who is locked out of the individual market until the next annual window, because they missed the shorter one and do not have a qualifying event to open a special enrollment period, is not just facing an abstract inconvenience. They are facing months without a plan to apply an ICHRA reimbursement against, at a point where the benchmark cost of the coverage they are missing runs several hundred dollars a month nationally, more in some counties. Meanwhile, the ICHRA contribution you budgeted for that employee sits unused, because there is usually nothing to reimburse against without an active individual policy. Nobody collects that money; it simply does not do the job you set it aside to do.

The size of the gap also depends on which calendar applies to that employee. Under the old Nov 1 to Jan 15 window, a missed deadline in early December still left roughly six weeks of runway before the window closed. Under the new Nov 1 to Dec 15 window, that same early-December slip has already run out the clock. The compressed calendar does not just shorten the window; it shortens how long a mistake stays fixable inside it.

A rollout checklist that assumes the shorter window

None of this requires new software or a vendor relationship to execute. It requires treating the compressed calendar as the default, not an edge case.

1. Confirm your state's exact 2027 dates before you build a calendar around them. FFM states already have Dec 15, 2026. SBM states, including Georgia, may not have published dates yet; check directly rather than assuming a repeat of last year.
2. Send the 90-day notice with real margin, not the exact minimum. A notice that clears the 90-day floor by a week still leaves employees the tighter but faster 60-days-before window; a notice with real margin leaves you room to fix a mistake.
3. Put the actual enrollment deadline, in calendar form, in a document separate from the legal notice. "60 days from your eligibility date" is correct and useless to an employee trying to plan a Tuesday afternoon. A specific date on a page gets used.
4. Schedule a mid-window check-in, not just a final reminder. With roughly a month less runway on the federal platform, there is less time left to fix a straggler if you wait until the final week to check who has not enrolled.
5. Treat SBM-state employees as a distinct group with their own risk. If Georgia Access has not published 2027 dates by the time you are finalizing your own calendar, build in a buffer rather than defaulting to "probably similar to last year."
6. Confirm affordability and set the contribution amount before any of the above. The reimbursement level determines whether the employee's marketplace premium tax credit is affected, and it should be settled before the notice goes out, not adjusted after employees have already started shopping.

Where employers get this wrong

Check your county before you build any of this

Everything above assumes an ICHRA already makes sense for your business. That is a separate question from the enrollment calendar, and it depends on where your employees actually live, not on a national average or even a state average. Cobb County and Montgomery County, both in our dataset above, sit in the same country under the same new federal enrollment deadline and still land 47 percentage points apart on estimated savings. A compressed enrollment window is not worth planning around if the underlying county economics do not support an ICHRA in the first place.

Ten minutes on the county map tells you whether the calendar work in this article is worth doing at all for your specific team. If your counties are marginal, that is your answer, and it costs you nothing to find out before building a rollout around a deadline that may not matter to your bottom line either way.

Where ICHRA Savings fits

Before anything else, check whether your county is one where an ICHRA estimate actually beats small group: ichrasavings.com/ichra-savings-map. That answer takes minutes. If the county math works in your favor, we help with the harder part: setting a contribution that clears the affordability test, structuring employee classes if you need them, and building the notice and enrollment calendar around the exact dates that apply to where your employees actually live, federal platform or state-run exchange.

If you want the mechanics before talking to anyone, start with how ICHRA works. If your renewal is already in hand and you are working against this year's compressed calendar, a short conversation now is worth more than another week of research on your own: ichrasavings.com/book.

Questions employers actually ask