As Marketplace health plan premiums rise and subsidies shift, employers are seeing more requests from employees (and their spouses) to drop Marketplace coverage and enroll in an employer-sponsored health plan mid-year. While this may feel straightforward, Marketplace rules and employer plan rules do not always work the same way.

In our January issue, we outlined the major compliance themes shaping 2026. This month, we build on that foundation with a deeper look at the annual updates, effective dates, and action steps employers need as the new year begins.