The ACA enrollment checklist for early retirees

By Tom, CPA · Updated October 25, 2026

TL;DR: Gather documents, build a careful MAGI estimate with a buffer below the 400% cliff, compare plans on total cost (premium plus expected out-of-pocket), confirm doctors and drugs, pay the first premium, and report income changes during the year. Open enrollment runs November 1 to January 15.

Educational only, not tax, legal, or investment advice. Examples are illustrations, not predictions. Rules and limits change; verify current figures and talk to a qualified professional about your situation.

Open enrollment, conquered with a checklist. For early retirees, the marketplace application isn't just paperwork; the income estimate you enter determines your advance premium tax credit and possibly cost-sharing reductions. With the 400% cliff back for 2026 coverage and repayment caps gone for tax years after 2025, a sloppy estimate can be expensive.

Open enrollment on HealthCare.gov runs November 1 to January 15. Enroll by December 15 for coverage starting January 1. State marketplaces can have different deadlines. Here's the checklist.

CPA Warning Label: The marketplace application asks for a number you can't know: next year's income. Answer it like someone who will have to reconcile it in April.

Documents

• Social Security numbers and dates of birth for everyone applying.
• Last year's tax return, to anchor your income estimate.
• Recent statements for IRAs, brokerage accounts and any pensions or annuities.
• Projected Social Security benefits, if anyone will claim during the year.
• Any employer coverage information, such as a spouse's job-based offer, using the marketplace's employer coverage tool.
• Current plan information and policy numbers, if renewing.
• A list of doctors, hospitals and prescriptions, with dosages.
• Immigration documents, if applicable.

Income estimate

The marketplace wants your expected household MAGI for the coverage year: AGI plus tax-exempt interest, non-taxable Social Security and excluded foreign income. Include income of dependents who are required to file.

1. Start with planned withdrawals and conversions. List each source: dividends, interest, capital gains (including year-end fund distributions), IRA withdrawals, Roth conversions, pensions, Social Security, part-time work.
2. Subtract above-the-line deductions like HSA contributions and deductible self-employed retirement contributions.
3. Compare the result with poverty line thresholds for 2026 coverage: 100% is $15,650 for one person and $21,150 for two; 400% is $62,600 and $84,600.
4. Keep a buffer below the cliff. Many early retirees leave several thousand dollars of room.
5. Check the floor. In non-expansion states, income below 100% of FPL may mean no subsidy; in expansion states, below 138% may mean Medicaid.
6. Document how you got the number in a short note. If the estimate is ever questioned, you'll want it.

Use the ACA subsidy calculator to test different MAGI levels.

Plan comparison steps

1. Preview plans with your estimate, ZIP code and household ages.
2. Note the benchmark: the second-lowest-cost silver plan, which sets your credit.
3. Check cost-sharing reductions. If your income is in the CSR range, compare silver plans' reduced deductibles. See cost-sharing reductions.
4. Check HSA options. Bronze and catastrophic plans are HSA-compatible starting in 2026.
5. Compare total cost: net premium plus expected out-of-pocket costs, and the worst case at the out-of-pocket maximum ($10,600 individual, $21,200 family in 2026).
6. Confirm doctors and hospitals in each plan's network directory, and call offices to confirm.
7. Confirm drugs on each plan's formulary, including tier and any prior authorization.
8. Consider plan type: HMO, EPO or PPO, especially if you travel.
9. Decide how much advance credit to take. You can take all, some or none in advance; taking less reduces the risk of repayment.
10. Add dental if needed; see dental and vision options.

After enrollment

• Pay the first premium (binder payment) by the insurer's deadline, or coverage won't start.
• Set up autopay and check that the amount reflects your credit.
• Save your eligibility notice and plan documents.
• Watch for requests to verify income or other information, and respond by the deadline.
• Get new ID cards and give them to your providers.
• Refill prescriptions under the new plan and confirm pricing.
• Keep Form 1095-A when it arrives in early the following year; you'll need it to file Form 8962. See premium tax credit reconciliation.

Mid-year updates

Report changes promptly, usually within 30 days. Changes that matter:

• Income changes, such as a bigger conversion, a large capital gain, or a new job.
• Household changes: marriage, divorce, a birth or a dependent moving out.
• Moving to a new ZIP code or state.
• Gaining other coverage, including Medicare or a job-based offer.

Illustration: Ellis, single, estimated MAGI of $45,000 and takes about $4,688 of advance credit for the year (benchmark $9,000). In July, a mutual fund sale adds $20,000 of gains, pushing MAGI to $65,000, above 400% of FPL ($62,600). If Ellis doesn't report it, the entire $4,688 must be repaid at tax time. If Ellis reports it in July, the marketplace can stop the advance credit, limiting the gap, though Ellis would still owe back credits already received for January through July. Better yet: Ellis could have checked the cliff before selling, perhaps harvesting losses or spreading the sale into January.

Turning 65 or other transitions

• If you or your spouse turn 65 during the year, plan Medicare enrollment and set the marketplace end date. Marketplace coverage doesn't end automatically. See the Medicare enrollment timeline.
• If you lose other coverage mid-year, you have 60 days to enroll through a Special Enrollment Period.

Final pre-submit check

• Income estimate entered and documented.
• Buffer below 400% of FPL, and above 100% or 138% if relevant.
• Household members correct.
• Doctors and drugs verified.
• Advance credit amount chosen deliberately.
• Deadline noted for the first premium payment.
• Calendar reminder set for next November 1.

Renewing an existing plan

If you already have marketplace coverage, you may be re-enrolled automatically, but automatic renewal is rarely the best deal for early retirees. Benchmarks change every year, your plan's price and network can change, and your income estimate almost certainly needs updating.

• Log in and update your income estimate before the renewal takes effect.
• Compare your current plan to this year's options; the cheapest plan last year often isn't this year.
• Check whether your benchmark changed, since your credit is tied to it.
• Recheck networks; insurers drop and add providers.
• Confirm the new net premium on your first bill of the year.

Illustration: choosing how much credit to take

Illustration: Rae, single, expects MAGI of $58,000, close to the $62,600 cliff. A surprise $5,000 of fund distributions would push her over. She qualifies for about $3,700 of credit on a benchmark of about $9,500. Rather than take all of it monthly, she takes $2,400 in advance and plans to claim the rest when she files if her income comes in as planned. If she crosses the cliff anyway, she repays $2,400 instead of $3,700. It's a small cost in monthly cash flow for a smaller worst case.