ACA plan crosswalk is the regulatory mechanism CMS uses to assign passively re-enrolled clients to a successor plan when their current coverage is discontinued or substantially modified at renewal. The client who does nothing between November 1 and December 15 ends up on whatever plan the carrier designated as the crosswalk target. That plan may cost more, cover different providers, or carry different cost-sharing than what the client had. The client may not find out until January.
Key Takeaways
- CMS crosswalk assigns a successor plan when the client's current plan is discontinued or substantially modified.
- The carrier selects the crosswalk target, not the client and not the Marketplace.
- Passive re-enrollment into the crosswalk plan happens automatically if the client takes no action by December 15.
- Premiums, network, and cost-sharing on the crosswalk plan can differ significantly from the prior plan.
- Brokers who surface crosswalk assignments early can move clients to a better plan during the active OEP window.
How CMS crosswalk works
When a carrier discontinues a plan for the next plan year, CMS requires the carrier to file a crosswalk designation identifying a successor plan. The successor does not have to be the most similar plan available; it has to meet CMS standards for the crosswalk filing. In practice, carriers typically designate the closest plan in the same metal tier from their own portfolio, but the determination is carrier-driven.
Once OEP opens, clients enrolled in a discontinued plan receive a renewal notice from the Marketplace. The notice identifies the crosswalk plan and the projected net premium after APTC. Clients who read and act on the notice can select any plan available in their rating area. Clients who do not act are passively re-enrolled into the crosswalk plan on January 1.
What changes at crosswalk
Three things can change when a client is crosswalked: the premium, the provider network, and the cost-sharing structure. Any one of these, or all three, can affect whether the crosswalk plan meets the client's needs.
The premium change is often the most visible. The crosswalk plan may have a different base premium than the prior plan, and APTC is recalculated annually based on the updated SLCSP benchmark. A client who paid $180 per month in the prior year may find themselves at $220 or $150 at renewal, depending on both the crosswalk plan premium and the updated subsidy.
The network change is often the most consequential. A client who was crosswalked from a PPO with broad out-of-network coverage to an HMO with a narrow network may not realize the difference until they try to see a provider who is no longer covered. Provider network verification is not automatic at passive re-enrollment.
Illustrative examples. Actual premium changes at renewal depend on the specific plan year rates, SLCSP benchmark in the rating area, and the client's household income and FPL percentage.
Crosswalk scenarios and broker actions
| Scenario | What happens | Broker action |
|---|---|---|
| Plan discontinued, crosswalk plan available | Client passively re-enrolls in the carrier-selected crosswalk plan. Premium and network may differ. | Review crosswalk plan in October. Compare to alternatives. Move client if a better fit exists. |
| Plan substantially modified (premium increase above threshold) | CMS may treat this as a discontinuation. Client may be crosswalked or may remain on the modified plan. | Check carrier renewal notices. If the modification is material, treat it like a discontinuation review. |
| Client's plan unchanged | Client passively re-enrolls in the same plan. Premium changes at renewal based on updated rates and APTC. | Still review: the same plan at a different premium may no longer be the client's best option. |
| Carrier exits market entirely | No crosswalk available. Client receives a termination notice. Coverage ends unless client acts. | Proactive outreach immediately. Client must actively select a new plan before OEP closes. |
The broker's window
Brokers with Agent of Record status on a client receive renewal notices from the Marketplace alongside the client. The October preview period, before OEP officially opens November 1, is when plan data for the new year becomes available in most states. This is when a broker who manages renewals actively can identify crosswalk assignments in their book and begin outreach.
The leverage point is the December 15 deadline in most FFM states, which is the last day to make a plan selection effective January 1. After December 15, changes made before January 31 are effective February 1. A client who was crosswalked to a plan with a higher premium and a narrower network and calls you in January has limited options until February.
Passive re-enrollment is not the same as no change
A client who is passively re-enrolled into an unchanged plan still experiences a premium change. Rates change annually, and APTC is recalculated based on the updated SLCSP benchmark. A client who never opens their renewal notice in a plan that was not discontinued may still see a material change in their net premium in January.
This is why renewal outreach cannot be limited to clients whose plans were discontinued. Every client in the book needs an annual review. The crosswalk scenario adds urgency when it applies, but the baseline workflow for plan year transitions applies to the full book.
Frequently asked questions
Common questions from brokers and clients about ACA plan crosswalk and passive re-enrollment at renewal.
What is an ACA plan crosswalk?
A plan crosswalk is the CMS process of mapping a discontinued or substantially modified plan to a successor plan at renewal. When a carrier discontinues a plan or changes it beyond a permitted threshold, CMS requires the carrier to designate a crosswalk target. Clients enrolled in the discontinued plan are automatically assigned to the crosswalk plan if they take no action during OEP.
Who chooses the crosswalk plan?
The carrier designates the crosswalk target plan. CMS reviews and approves the assignment, but the selection is carrier-driven. The client has no input into which plan they are crosswalked to. The only way to end up on a different plan is to take active action during OEP and select one.
Can a client's APTC change at crosswalk renewal?
Yes. APTC is recalculated at renewal based on the updated SLCSP benchmark and the client's reported income. If the crosswalk plan has a different premium than the prior plan, and if the SLCSP benchmark changes, the net premium after APTC will differ. Clients who do not actively review the renewal notice may not notice the change until the first January payment.
What is passive re-enrollment?
Passive re-enrollment is the automatic continuation of a client's coverage into the next plan year without the client taking any action. If the client's plan is unchanged, they remain on the same plan. If the plan is discontinued, they are crosswalked to the successor plan. Either way, if the client does not log in and actively select a plan, their coverage continues automatically.
How does crosswalk affect a broker's book of business?
Clients who are crosswalked may end up on plans with different networks, different formularies, or significantly different premiums. If a broker does not actively review the crosswalk assignment for their book, they may find clients on plans that no longer serve them well. Proactive outreach in October and November, before OEP closes, is how brokers retain clients and prevent post-renewal complaints.
What happens if a plan has no crosswalk target?
If a carrier exits the market entirely or discontinues all plans in a service area with no successor plan, clients in that area are not passively re-enrolled. They receive a notice that their coverage will terminate and must actively select a new plan. This is a harder situation than a crosswalk because the client must take affirmative action or lose coverage.
