ACA Passive Re-Enrollment: A Client Follow-Up Workflow
About one in five ACA clients renew passively each year. Here's a repeatable workflow for finding the ones with a subsidy or premium problem and reaching them before the plan-change deadline.
Why a passively renewed ACA client still needs a phone call When the Marketplace auto-renews a client's ACA plan, that client is covered on January 1 whether or not anyone talks to them — but "covered" is not the same as "covered correctly." A passive renewal can quietly change the client's insurer, raise the premium, or wipe out their subsidy, and none of that shows up unless someone checks. The fix is a short, repeatable follow-up workflow: pull the list of renewed clients from your book, flag the ones with a subsidy or payment problem, and call before the plan-change window closes. What actually happens during automatic re-enrollment During Open Enrollment, the Marketplace sends a letter telling each client whether they'll be automatically re-enrolled, and in what plan. If the client's current insurer isn't offering a similar plan for the next year, the Marketplace re-enrolls them in a comparable plan with a different insurer — a detail a lot of clients miss when they skim the letter. Passive renewal coverage starts January 1, and clients can still change plans through the end of Open Enrollment, which HealthCare.gov's own dates page currently lists as January 15 ( Open Enrollment runs November 1 – January 15 ). Enrolling or switching by December 15 keeps a January 1 effective date; a change made between December 16 and January 15 starts February 1 instead ( HealthCare.gov, Automatic re-enrollment keeps you covered ). Passive renewal isn't a rare edge case. KFF's analysis of HealthCare.gov enrollment found that 21% of enrollments were passive re-enrollments in 2021–2023, rising to 22% in 2024 — roughly one in five clients on your ACA book did nothing to confirm their coverage for the new year. A regulatory note for this cycle: CMS's 2025 Marketplace Integrity and Affordability final rule describes shortening the Open Enrollment Period to end December 15, "beginning with the OEP for plan year 2027" ( CMS, 2025 Marketplace Integrity and Affordability Final Rule fact sheet ). As of this writing, HealthCare.gov's own consumer-facing pages still list the window as November 1 – January 15. Confirm the live deadline on HealthCare.gov (or your state-based marketplace's site) before you build your call schedule — it's the detail most likely to have moved by the time you read this. Four things a passive renewal can get wrong The insurer changed. If the prior carrier didn't file a similar plan, the client is now with a different company, possibly with a different network — their doctor or prescription may no longer be in-network. The premium changed and the client doesn't know it. Auto-renewed clients rarely see the new premium until the first bill, or the first missed payment. The subsidy dropped to zero. A data-matching issue, an income change the Marketplace couldn't verify, or an expired special circumstance can zero out the advance premium tax credit on a renewal that otherwise looks routine. The household changed and the application didn't. A birth, a job change, a dependent turning 26 — none of it updates automatically. The client is now over- or under-subsidized and may face a surprise at tax time. Build the follow-up list from your book, not from memory You don't need to call every ACA client individually to find the ones with a problem — the HealthSherpa export you already pull can tell you who they are. AgencyView's ACA Marketplace Book of Business report reads that export and flags exactly the records this workflow needs: a Renewal Status on every row so you can filter to clients whose current-year policy is a renewal, a dedicated $0 APTC list of active and pending applications currently showing no tax credit, and an Agent-of-Record list showing which clients have already moved to another agent (so you don't call clients who aren't yours to call). Each row links straight to the client's record in your CRM. That gives you a short, prioritized list instead of a spreadsheet you have to build by hand: passive renewals with $0 APTC first (most likely to have a real problem), then passive renewals with a payment past due, then everyone else on a passive renewal as time allows. The follow-up workflow, step by step Pull the renewal and $0 APTC lists before December 15. That's the deadline that keeps a plan change effective January 1 under the current published rules — build your calling schedule backward from it, and re-check the live deadline first per the note above. Segment before you dial. Passive renewal + $0 APTC + a payment issue is your first call list. Passive renewal alone is your second. Clients who actively re-enrolled don't need this call at all. Call or text, and check for an opt-out first. If you're working from your CRM record, check the contact's texting status before sending anything — a client who has opted out by replying STOP shouldn't get a follow-up text, only a call or a letter. Confirm three things on the call: the plan and insurer they're actually enrolled in, the premium they'll actually pay, and whether their household or income has changed since they last updated their application. Re-quote if anything changed. If the household changed or the client wants a different plan, requote and re-enroll from the client's own record rather than starting a new application from scratch — see quoting and enrolling from the contact record for how that flow works. Log the call and set a January 15 checkpoint. Note what you confirmed, then set a reminder for clients you couldn't reach the first time — they still have until Open Enrollment ends to make a change, and a second attempt before the window closes is worth the five minutes. Where this fits with your broader OEP readiness This follow-up workflow is deliberately narrow — it's about the clients who are already on your book and already renewed, not the agency-wide prep work of getting ready for Open Enrollment in the first place. If you haven't built out your season readiness plan yet, start with an agent's readiness checklist for ACA Open Enrollment , then run this follow-up pass once your book of business report shows who actually renewed passively. Texting is often the fastest way to get a passively renewed client to respond, but it only works if you're not guessing who has opted out — see what agents actually need from CRM texting for how opt-in and opt-out status should show up next to the conversation itself, not buried in a separate settings page. FAQ What is ACA passive re-enrollment? It's when the Marketplace automatically re-enrolls a client in a plan for the new year — the same plan if the insurer is still offering it, or a comparable plan with a different insurer if not — because the client didn't log in to actively choose or confirm a plan during Open Enrollment. How do I know which of my clients were passively renewed? Your HealthSherpa export includes a renewal indicator on each record. Reading that export into a report with a Renewal Status column, like AgencyView's ACA Marketplace Book of Business report, turns it into a filterable list instead of a raw spreadsheet. Why does $0 APTC matter on a renewal? A renewal showing no premium tax credit today may mean the client's subsidy didn't carry over — from an income change, an expired special circumstance, or a data-matching issue — and they could be paying full price without realizing it. It's a snapshot, not proof the credit was lost, so it belongs on your call list for verification, not on a "problem confirmed" list. When is the deadline to change a client's plan after a passive renewal? Under the dates HealthCare.gov currently publishes, changing plans by December 15 keeps a January 1 effective date, and a change made after that but before Open Enrollment ends still takes effect February 1. Confirm the live end date before you finalize your calendar — see the regulatory note above. Can I text a client about their renewal instead of calling? You can, but check the contact's SMS status first. A client who has opted out…
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