CMS finalized the HHS Notice of Benefit and Payment Parameters for 2027 on May 15, 2026, and news coverage of the consumer-cost effects broke three days later (STAT, May 18, 2026). The final rule expands catastrophic plan eligibility for the 2027 plan year, rewrites the federal actuarial value calculator in ways that push higher out-of-pocket costs at every metal tier, and pares back standardized plan offerings that let consumers compare across issuers on equal footing. The package lands on top of the One Big Beautiful Bill Act enhanced-premium-tax-credit rollback this site is covering in a companion piece this week documenting the Georgia, North Carolina, and Ohio marketplace-enrollment declines (Black Health, May 22, 2026).
The two federal actions hit the same enrollees from both sides of the affordability equation. Premium tax credits shrink. Plans get thinner. Out-of-pocket exposure climbs.
The 2027 plan year carries three rule changes Black marketplace enrollees should track
The first change is the actuarial value calculator rewrite. Actuarial value is the share of healthcare costs a plan is designed to cover; the federal calculator sets the methodology that lets a plan call itself silver, gold, bronze, or platinum. The 2027 calculator forces platinum plans and the 94-percent-AV cost-sharing-reduction silver plans into substantially higher cost-sharing, removes the maximum-out-of-pocket compliance filter that previously rejected plans exceeding statutory MOOP limits, and incorporates out-of-network emergency claims data per the No Surprises Act (Jason Levitis of the Urban Institute and Sabrina Corlette of the Georgetown Center on Health Insurance Reforms, writing for State Health and Value Strategies on April 30, 2026). The bottom-line consumer effect: higher out-of-pocket expenses at any given metal tier and reduced premium-tax-credit purchasing power because silver-plan premiums drop along with the silver-plan benefit design.
The second change is catastrophic plan expansion. Catastrophic coverage was previously restricted to enrollees under 30 or those with a hardship exemption. The final rule broadens the eligibility pool, the cheaper-premium-higher-deductible substitute insurers have lobbied for since the ACA's 2014 rollout. STAT's reporting on the package summarized the trade in plain terms: "The Trump administration is opening the floodgates for Affordable Care Act exchanges to feature plans that offer bare-bones coverage and fewer protections, but which have lower monthly premiums" (STAT, May 18, 2026). The reporting documents that the rule pares back the ACA's prior restriction of high-deductible catastrophic plans to a small subset of enrollees, the structural change behind the broader eligibility.
The third change is the standardized plan pullback. Standardized plans, introduced under the prior administration, required issuers offering qualified health plans on the federal marketplace to offer at least one plan at each metal tier with a uniform cost-sharing structure. The 2027 rule pares back that requirement, one of the package elements STAT's reporting names explicitly (STAT, May 18, 2026). The uniformity rule let a consumer compare insurer A's silver against insurer B's silver on a single variable: premium. Stripping that requirement returns the marketplace to the pre-2022 design, where each issuer's bronze, silver, and gold differed across deductible, copay, and coinsurance in ways that make apples-to-apples comparison harder for any consumer without a navigator.
The CMS rule stacks on the OBBBA enhanced-PTC rollback
The first half of the squeeze is already documented in our coverage of the OBBBA enhanced-PTC rollback. OBBBA, signed into law in 2025, did not renew the enhanced premium tax credits the American Rescue Plan introduced in 2021 and the Inflation Reduction Act extended through 2025. Subsidies reverted to pre-2021 amounts for the 2026 plan year. Average annual out-of-pocket premium for subsidized marketplace enrollees rose from $888 to $1,904, a 114 percent jump per KFF marketplace-affordability tracking carried in our prior piece. National marketplace enrollment fell from 24.3 million for 2025 to 22.8 million for 2026 (CMS Marketplace 2026 Open Enrollment Period Report). Georgia lost 37 percent of its marketplace enrollment between January 2025 and April 2026, documented in this site's companion OBBBA-ACA piece citing Georgia Recorder reporting. Federal health policy moved in two directions this month: the Supreme Court rejected pharmaceutical-industry challenges to Medicare drug-price negotiation on May 18, preserving negotiated-price savings on the Medicare side; the CMS rule landed in the same week, tightening ACA marketplace plan design on the exchange side.
The CMS final rule is the second half. The same enrollees who saw premium subsidies pull back in 2026 face thinner plan design and higher out-of-pocket exposure in 2027. Sabrina Corlette, J.D., research professor, founder, and co-director of the Center on Health Insurance Reforms at Georgetown University's McCourt School of Public Policy, co-authored a February 19, 2026 CHIR analysis of the proposed version of this rule documenting the structural concern: provisions on actuarial value flexibility and standardized plan reductions shift cost exposure from issuers and federal taxpayers to enrollees, including the lower-income marketplace consumers most reliant on the cost-sharing-reduction silver plans the calculator rewrite hits hardest (CHIR, February 19, 2026). This site has a written-quote request out to Corlette on the final rule; we will Updated: addendum the piece on reply.
Where the squeeze lands: state-by-state Black-marketplace-enrollee shares
The CMS rule applies nationally. The exposure is not evenly distributed. KFF state-level Marketplace plan selections by race and ethnicity for the 2026 Open Enrollment Period document the concentration (KFF, April 2026):
Maryland: 20.41 percent Black share of 255,612 total Marketplace enrollees, roughly 52,170 Black enrollees. Mississippi: 14.28 percent of 313,392, roughly 44,750. Georgia: 9.72 percent of 1,324,295, roughly 128,540. Louisiana: 7.30 percent of 296,648, roughly 21,650. South Carolina: 6.96 percent of 587,567, roughly 40,895. Florida carries the largest absolute Black-marketplace-enrollee count at approximately 257,764. Together, the Florida-Georgia-North-Carolina-South-Carolina-Louisiana-Mississippi-Maryland concentration accounts for the majority of identified Black marketplace enrollment nationally.
Two methodology limits sit underneath those numbers. KFF's state indicator counts a consumer in a race category only if the consumer did not also attest to Hispanic or Latino ethnicity, and HealthCare.gov's race-and-ethnicity field is missing or unknown for a substantial share of plan selectors per HHS Assistant Secretary for Planning and Evaluation 2024 imputation methodology. The actual Black-enrollee counts run higher than the directly reported numbers; the state-concentration pattern holds independent of the imputation cell.
What to do this week
Three concrete actions for Black marketplace enrollees considering 2027 coverage.
First, before you re-enroll for 2027, verify the actuarial value of the plan you are picking. The metal-tier label is no longer a reliable single-number guide to out-of-pocket exposure under the 2027 calculator changes. On HealthCare.gov, the Plan Compare tool lists each plan's estimated total yearly cost for your specific household income and expected use; that number is the operational figure to compare across plans, not the metal-tier label. Compare three plans at the same income input before you pick.
Second, talk to a navigator before you enroll. Navigators are federally trained, free, and exist precisely to translate plan-comparison math you should not have to do alone, especially in a year when the underlying plan design rules just changed. Find one through the Healthcare.gov Find Local Help directory or the Get Covered Connector directory operated by Get America Covered, the navigator-coordination nonprofit. Both are free.
Third, if your state runs its own marketplace, check what your state has done independently of the federal rule. Maryland, California, New York, Massachusetts, Washington, New Jersey, Pennsylvania, Connecticut, Colorado, Minnesota, Rhode Island, Vermont, Kentucky, Maine, Nevada, New Mexico, Virginia, Idaho, and the District of Columbia all operate state-based exchanges; several have moved to backstop the federal PTC rollback or constrain the actuarial value latitude the federal calculator now allows. The CMS State-Based Marketplaces page lists state-marketplace contacts. If you are in a state-based exchange state, the rules you face at re-enrollment may differ from the federal default.
Citations
- CMS. HHS Notice of Benefit and Payment Parameters for 2027 Final Rule Fact Sheet. May 15, 2026. https://www.cms.gov/newsroom/fact-sheets/hhs-notice-benefit-payment-parameters-2027-final-rule.
- Goldhill O. Trump's CMS to allow skimpier plans on ACA exchanges. STAT. May 18, 2026. https://www.statnews.com/2026/05/18/trump-aca-insurance-new-cms-rules-expand-catastrophic-coverage/.
- Levitis J (Urban Institute), Corlette S (Georgetown CHIR). Changes to the Actuarial Value Calculator for 2027. State Health and Value Strategies. April 30, 2026. https://shvs.org/changes-to-the-actuarial-value-calculator-for-2027/.
- Corlette S, Levitis J, Straw T. Proposed Marketplace and Insurance Changes in the 2027 Notice of Benefit and Payment Parameters: Implications for States. Center on Health Insurance Reforms, Georgetown University McCourt School of Public Policy. February 19, 2026. https://chir.georgetown.edu/proposed-marketplace-and-insurance-changes-in-the-2027-notice-of-benefit-payment-parameters-implications-for-states/.
- CMS. Plan Year 2026 Marketplace Plans and Prices Fact Sheet. https://www.cms.gov/newsroom/fact-sheets/plan-year-2026-marketplace-plans-prices-fact-sheet.
- KFF. Marketplace Plan Selections by Race/Ethnicity. State Health Facts. April 2026 update. https://www.kff.org/affordable-care-act/state-indicator/marketplace-plan-selections-by-raceethnicity/.
- HHS Assistant Secretary for Planning and Evaluation (ASPE). HealthCare.gov Plan Selections by Race and Ethnicity in the 2024 Marketplace Open Enrollment Period. https://aspe.hhs.gov/sites/default/files/documents/7f692cf92e773414b632cb408394b21d/race-ethnicity-marketplace-2024-oep-ib.pdf.
- Black Health Editorial team. Black families in non-expansion states are losing ACA coverage after OBBBA killed the enhanced premium subsidies. Here is what to do this week. May 22, 2026. https://www.blackhealth.org/articles/obbba-aca-subsidies-rollback-black-coverage-loss-rural-hospitals/.
- HealthCare.gov Plan Compare tool. https://www.healthcare.gov/see-plans/.
- HealthCare.gov Find Local Help directory. https://localhelp.healthcare.gov/.
- Get Covered Connector. https://connector.getcoveredamerica.org/.
- CMS. State-Based Marketplaces. https://www.cms.gov/marketplace/about/oversight/marketplaces.
