If you are a Florida employer heading into 2027 renewals, expect more workers asking about your health plan. After enhanced ACA premium tax credits expired on December 31, 2025, HealthCare.gov enrollment fell 13 percent from its 2025 peak, and Urban Institute modeling estimated that 3.2 million more people would move into employer-sponsored insurance in 2026 than if the enhanced subsidies had remained in place. This checklist walks Florida employers through eligibility, affordability, and enrollment capacity, as of October 21, 2026.
Why workers are shifting toward employer coverage
Three forces are pushing workers from the individual Marketplace toward coverage through work:
- The enhanced premium tax credits expired. The House passed a three-year extension (H.R. 1834) on January 8, 2026, but it stalled in the Senate, so the original ACA rules apply for 2027: a sliding-scale credit up to 400 percent of the federal poverty level and a hard cliff above it, meaning one dollar over 400 percent FPL means no credit.
- CMS enforcement tightened the Marketplace. The Centers for Medicare & Medicaid Services canceled about 315,000 Marketplace enrollments covering more than 760,000 people on August 31 after finding them unauthorized, and froze new agents and brokers from entering the federally facilitated Marketplace until February 1, 2027. That matters because agents and brokers handled 76 percent of the 10.8 million active HealthCare.gov plan selections during 2026 open enrollment.
- Individual coverage got more expensive and thinner. Bronze plans accounted for 40 percent of 2026 selections, up from 30 percent a year earlier, while average deductibles climbed 37 percent to a record $3,786, according to KFF analysis of 2026 Marketplace coverage.
What the shift means for Florida employers
The employers most likely to feel the pressure are the ones whose workers previously relied on Marketplace coverage. Access to group coverage is uneven across workforces. According to KFF’s 2025 Employer Health Benefits Survey, 80 percent of workers at firms offering health benefits are eligible for the company plan, but that rate falls to 67 percent at firms with large numbers of lower-wage workers and to 53 percent in retail. Just 27 percent of large firms offering health coverage make it available to part-time employees.
Under the ACA, employees averaging at least 30 hours a week count as full time for employer shared-responsibility purposes. Expanding eligibility beyond that is a benefits and workforce decision, not a new federal requirement. For employers with 50 or more full-time equivalents, the stakes are financial as well as operational: if a full-time employee gets a Marketplace premium tax credit because your offer was not affordable or not offered, penalty exposure can follow.
The 2027 readiness checklist for Florida employers
1. Review who your plan covers right now
Pull your plan document and summary plan description and confirm your current rules: how full-time status is defined, whether part-time employees can enroll, and how long new hires wait for coverage. Federal law caps health plan waiting periods at 90 calendar days. If you are considering expanding eligibility, talk with benefits counsel before changing plan documents or payroll practices.
2. Confirm affordability if you are an Applicable Large Employer
For plan years beginning in 2027, the IRS affordability threshold is 10.22 percent of household income. Test your employee contribution for the lowest-cost self-only plan that provides minimum value against the three safe harbors: W-2 wages, rate of pay, and the federal poverty line. This review belongs in your renewal process, not after open enrollment opens.
3. Stress-test onboarding and enrollment communications
More inquiries mean more paperwork moving at once. Confirm your hiring packets still include the required Marketplace notice for new hires, that your election system can handle a larger enrollment wave, and that you know your carrier’s census and enrollment deadlines ahead of the renewal. Missing a carrier deadline can delay coverage starts for your whole group.
4. Model higher take-up in your renewal budget
If more eligible workers enroll, your total employer contribution rises even when per-employee costs stay flat. Model a higher participation scenario against your current contribution strategy so the renewal decision reflects reality, not last year’s headcount.
5. Weigh defined-contribution alternatives
A group plan is not the only route. The CHOICE Arrangement (the rebranded ICHRA) lets employers of any size reimburse employees for individual coverage with no annual cap, and a QSEHRA works for employers under 50 with no group plan. Some employers also pair a core plan with supplemental employee-benefits programs. CB Premier Benefits, for example, is a supplemental employee-benefits program offered through Coverage Babe, not insurance and not a replacement for major medical. Ask your agent what layers fit your workforce and budget.
6. Confirm your agent support before open enrollment
Open enrollment for 2027 runs November 1, 2026 through January 15, 2027, and Florida employers should be comparing quotes and plan designs well before then. A Florida-licensed health insurance agent can run the comparisons, check networks, and walk through contribution options with you. Coverage Babe’s Sean Wigand and Lishele Wigand are Florida-licensed health insurance agents who work with Florida businesses on group coverage.
Compliance watch-outs before you act
- Your plan document and summary plan description control eligibility, waiting periods, and benefits. This article is general information, not tax or legal advice. Confirm affordability testing, penalties, and document changes with your CPA or benefits counsel.
- No one can guarantee savings or outcomes. Any figures above come from the cited sources and are date-stamped as of October 21, 2026. Rules, rates, and deadlines change.
- This guidance is written for Florida employers. Coverage Babe’s agents are licensed in Florida.
Frequently asked questions
Do we have to offer coverage to part-time employees?
There is no new federal requirement to expand eligibility to part-time workers. The ACA shared-responsibility rules apply to full-time employees (30 or more hours per week) at applicable large employers. Whether to widen eligibility is a workforce and benefits decision. Review the tradeoffs with your agent and benefits counsel.
We have fewer than 50 employees. Does any of this apply to us?
The employer mandate does not apply below 50 full-time equivalents, but the competitive pressure does. If your workers are losing affordable individual options, a group plan, a CHOICE Arrangement, or a QSEHRA can become a hiring and retention advantage. An agent can compare the routes for your headcount and budget.
What if our employees cannot afford our plan’s contributions?
Review your contribution strategy against the 2027 affordability safe harbors, revisit plan design options at renewal, and ask your agent about supplemental benefits that can sit alongside the core plan. High employee contributions that push workers to the Marketplace can also create ALE penalty exposure.
When should we start preparing?
Start 60 to 90 days before your renewal. Eligibility reviews, affordability testing, and carrier census work all take longer than employers expect, and open enrollment season compresses everyone’s timelines.
Talk through your 2027 renewal with a Florida-licensed agent
If more of your workers are about to look to your company for coverage, now is the time to review eligibility, affordability, and plan design. Book a consultation with Coverage Babe to walk through your options before your renewal locks in. Learn more about Coverage Babe or explore CB Premier Benefits, our supplemental employee-benefits program.