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Active 2026 issue

Hit the ACA cliff? Here's what to actually do.

The Inflation Reduction Act's enhanced ACA subsidies expired Dec 31, 2025. For 2026, the Marketplace reverted to the pre-IRA schedule — including the 400% FPL cliff. If your 2026 household income lands above the cliff, you owe the full premium. KFF modeled a 60-year-old couple at $85k seeing a $22,600/yearincrease. Here's what Wisconsin households can actually do about it.

First: confirm you're actually over the cliff

The cliff sits at 400% of the Federal Poverty Level for your tax household size. For 2026, that's roughly:

  • 1 person: over $60,240/yr
  • 2 people: over $81,760/yr
  • 3 people: over $103,280/yr
  • 4 people: over $124,800/yr

Important: the Marketplace uses projected 2026 MAGI, not 2025 actuals. If your income is variable (self-employed, retirement drawdown, capital gains, freelance), your real number for the year may end up under the cliff after deductions. Talk to a tax preparer before you assume you're hit.

Run our income calculator to see exactly which programs you cross or miss at your projected 2026 MAGI.

Path 1 — Lower your projected MAGI under 400% FPL

The cliff is binary. $1 below the threshold and you get an APTC of likely thousands per year; $1 above and you get zero. So lowering MAGI by a few thousand is sometimes the highest-ROI move you can make all year.

Legitimate ways to reduce projected MAGI:

  • Traditional IRA contribution.$7,000 in 2026 ($8,000 if 50+). Deductible if you don't have an active employer 401(k) — phaseouts apply if you do.
  • HSA contribution.Only if you're on a qualifying HDHP. Limits: $4,400 self-only, $8,750 family in 2026. Anyone 55+ can add $1,000.
  • Self-employed retirement (SEP-IRA / Solo 401(k)). Up to ~25% of net self-employment earnings. The single biggest lever for freelancers and consultants.
  • Self-employed health insurance deduction. Premiums you pay for ACA coverage are themselves deductible from MAGI when you're self-employed — and that deduction can drop you under the cliff. There's an iterative-calculation issue with this one (the deduction depends on the subsidy, which depends on the deduction); tax software handles it but your CPA may need to plug it in twice.
  • Business expense recognition. Self-employed people: bunch deductible expenses into 2026 instead of stretching them across years. Section 179 / bonus depreciation on equipment. Home-office deduction if you qualify.
  • Charitable contributions / Donor-Advised Fund. Doesn't reduce MAGI directly — but if you itemize and it shifts AGI, it can move the dial enough to matter.
  • Defer income.Push a December bonus or client invoice into January 2027 — fully legal as long as the work isn't already done and accepted.

What does NOT count: capital losses (offset capital gains, not other income, beyond a $3k cap), 401(k) loans (not income reduction), Roth IRA contributions (post-tax, no MAGI effect).

Path 2 — Catastrophic plan (under 30, or hardship exemption)

Catastrophic plans have very low monthly premiums and very high deductibles (~$10,000 single in 2026). They're ACA- compliant and cover the same essential health benefits as metal plans, plus 3 primary-care visits before the deductible. They are NOT eligible for APTC, but most people considering them on the cliff path don't qualify for APTC anyway.

Eligibility:

  • Under 30 at any point in 2026 — automatic.
  • 30+ with an affordability hardship exemption. If the cheapest Bronze plan available to you costs more than ~8.39% of your household income, you can apply for a hardship exemption that unlocks Catastrophic eligibility (and an exemption from any state-level individual mandate). This is the path many cliff-affected 60-somethings overlook.
  • 30+ with another hardship(homelessness, eviction, domestic violence, recent bankruptcy, ineligible for Medicaid in a non-expansion state — yes, that's literally Wisconsin's situation for the coverage gap).

Catastrophic plans cover the worst-case (hospital stay, cancer diagnosis, accident) — which is the actual purpose of having health insurance. The deductible is large but bounded; without insurance, a single ICU stay can be $200k+. This is notthe same thing as “junk” short-term insurance described below.

How to apply: on HealthCare.gov, enter your info; if a Catastrophic plan is available based on age, it shows up. For the hardship exemption path you submit Form OMB 0938-1190 (download from healthcare.gov/exemptions). Expect 2–6 weeks for approval; Marketplace will give you a retroactive effective date.

Path 3 — Split the household across programs

The cliff is per-tax-household, but Medicaid is per-person. Some Wisconsin households at 400%+ FPL can still split:

  • Children up to 300% FPLqualify for BadgerCare Plus regardless of parents' income (with a sliding-scale premium between 200–300% FPL). At 400%+, kids are over even that ceiling — but they're cheap to insure on the Marketplace because the ACA only counts the three oldest under-21 children, and child rates are 76.5% of the age-21 anchor.
  • Pregnant residents qualify for BadgerCare+ up to 306% FPL — household income tested at the household level but coverage applies to the pregnant person and the baby for 12 months postpartum.
  • One spouse on Medicare.If one of you turns 65, that person leaves the Marketplace pool entirely. The remaining spouse 's subsidy math is recomputed against a household-of-one income, which often unlocks APTC even when the joint income was above the cliff.
  • SeniorCare for 65+ Rx.Wisconsin's state Rx assistance program isn't income-tested at the same threshold as APTC. Even a household at 400%+ FPL might qualify for SeniorCare Level 2b (up to 240% FPL Level 2a; no upper limit on Level 3, just a higher deductible). See SeniorCare vs. LIS.

What NOT to do

Several “cheap insurance” alternatives are heavily marketed to people hit by the cliff. Most are traps.

  • Short-term limited-duration insurance (STLDI). Federal rules tightened in 2024 — STLDI plans can no longer extend past 4 months. They are NOT ACA-compliant: they can deny pre-existing conditions, exclude prescription drugs, cap lifetime payout. A 60-yo who buys STLDI then has a heart attack in month 5 is uninsured at the moment they need it most. If you're considering this for a literal 2-month gap before Medicare kicks in, fine; for a full calendar year as primary coverage, it's catastrophically risky.
  • Healthshares / Christian medical-cost-sharing. Not insurance — explicitly exempt from ACA rules and from state insurance regulators. They 'share' what they choose, can deny pre-existing conditions, and have no obligation to pay claims at all. Some are well-run; most shouldn't be your only coverage. Wisconsin has had multiple consumer-protection cases against healthshare operators in the last decade.
  • “Hospital indemnity” or “accident only” plans as primary coverage. Pay you a flat amount per hospital day. Useful as supplemental coverage (Aflac-style), useless as primary.
  • Going uninsured.CBO models 2.2M additional uninsured Americans in 2026. The expected cost of a serious medical event vastly exceeds even the cliff-priced premium — if you're going to spend $1,500/mo, do the math on what one ICU stay costs without coverage. The federal individual-mandate penalty is $0; the practical exposure is unbounded.

If you're close to 65

Cliff math gets a lot less brutal when Medicare arrives. A 60-year-old has 5 expensive years to bridge; a 64-year-old has 1. Strategies that compound that proximity:

  • Accelerate retirement-account drawdowns to before 65.Once you're on Medicare, RMDs and high MAGI don't cost you APTC anymore — they only affect IRMAA (the income-related Part B premium surcharge), which tops out far above the cliff.
  • Don't miss your IEP. Even a brief uninsured stretch right before Medicare kicks in is workable; missing the 7-month Initial Enrollment Period triggers a lifetime Part B late-enrollment penalty (10% per year missed). See our pre-Medicare timeline.
  • Wisconsin Medigap Open Enrollmentkicks in for 6 months after Part B starts. It's the ONLY window when carriers can't medically underwrite. Do not enter Medicare with a chronic condition and then try to buy Medigap a year later — you may be locked out.

Most cliff-affected households we've modeled are best served by:

  1. Run the numbers on whether MAGI-lowering moves are feasible for 2026. A few hundred dollars of traditional IRA contribution can be the difference between $0 and $15,000 of APTC.
  2. If MAGI can't move enough, buy the cheapest Bronze planon the Marketplace — this is what the law assumes you'll do, and it's ACA-compliant so pre-existing conditions stay covered.
  3. If you're under 30 or qualify for the affordability hardship, switch to a Catastrophic plan — same essential benefits, lower premium, much higher deductible.
  4. Re-check coverage every quarter. Income drops, family-size changes, pregnancy, or a 65th birthday can re-open APTC mid- year via a Special Enrollment Period.

Sources: KFF (2026 premium projections); CBO Report R48290 (uninsured projections); 26 USC §36B (premium tax credit statute); 45 CFR §155.605 (hardship-exemption catastrophic eligibility); HHS Notice of Benefit and Payment Parameters 2026 (Catastrophic plan rules); WI DHS BadgerCare Plus eligibility handbook.