The ENROLL Act of 2025 amends the Affordable Care Act’s navigator program to change who receives grants, what navigators must do, and how federal exchanges are funded. The bill directs federally‑operated Exchanges to use new selection criteria, requires navigators to provide clearer public education, and imposes an in‑state, in‑person assistance requirement.
The measure also creates a permanent funding stream for navigator grants on federally‑operated Exchanges by obligating $100 million annually from the user fees assessed on participating issuers, with those funds remaining available until expended. The changes apply to plan years beginning on or after January 1, 2026.
At a Glance
What It Does
For Exchanges run by HHS within a State under 1321(c), the bill requires grant awards to be based on an entity’s demonstrated ability to perform the navigator duties listed in statute, forbids considering whether the applicant will provide information about non‑qualified group plans, and requires at least one award each year to a community and consumer‑focused nonprofit. It expands the navigator duties to cover State Medicaid and CHIP programs and plain‑language public education, allows year‑round performance of duties, and adds a requirement that navigators maintain an in‑state physical presence to provide in‑person help.
Who It Affects
Federally‑facilitated Exchanges and their grant recipients, certified navigator organizations, community and consumer‑focused nonprofits seeking navigator grants, health insurance issuers subject to Exchange user fees, and consumers who rely on in‑person and outreach assistance—including Medicaid and CHIP applicants.
Why It Matters
The bill ties navigator funding to insurer user fees for federal exchanges, guarantees an avenue for community nonprofits to receive grants, and shifts navigator responsibilities toward clearer, year‑round outreach including Medicaid/CHIP—changing compliance expectations for navigator programs and the administrative priorities of federally‑operated Exchanges.
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What This Bill Actually Does
The ENROLL Act amends section 1311(i) of the ACA to change how federal Exchanges select and fund navigators and to expand what navigators must do. For Exchanges operated by HHS under section 1321(c) (often called federally‑facilitated Exchanges), the bill tells the Exchange to judge grant applicants by their documented ability to perform the statutory navigator duties rather than other factors.
It also instructs Exchanges not to factor into award decisions whether an applicant plans to provide information about employer or other group health plans that are not qualified health plans—effectively narrowing the Exchange’s ability to require navigators to advise on non‑QHP group coverage.
The bill broadens the scope of navigator duties: navigators must now be equipped to provide information about State Medicaid plans (title XIX) and State Children’s Health Insurance Programs (title XXI) in addition to qualified health plans. The bill adds an explicit duty to conduct plain‑language public education about QHP requirements and protections and clarifies that navigators may perform any of their duties at any point during the year (not only during open enrollment).On program structure, the ENROLL Act requires that, each year, the federally‑operated Exchange award at least one navigator grant to a community and consumer‑focused nonprofit group—an affirmative floor for community organizations.
It also adds an operational requirement that navigator entities maintain a physical presence in the State so they can provide in‑person assistance to consumers, which introduces location and potentially office‑space expectations for grantees.Finally, the bill creates a dedicated funding line for navigators on federal Exchanges by directing the Secretary to obligate $100,000,000 each fiscal year from the user fees charged to participating issuers (per 45 C.F.R. §156.50 or successors). Those funds are to remain available until expended.
The effective date ties the changes to plan years beginning January 1, 2026, so Exchanges and applicants will need to adjust grant practices and operational plans before that enrollment cycle.
The Five Things You Need to Know
For federally‑operated Exchanges under section 1321(c), the Exchange must base navigator grants on an applicant’s proven capacity to perform the statutory duties rather than on promises to advise about non‑qualified group plans.
The bill explicitly adds State Medicaid (title XIX) and CHIP (title XXI) to the list of coverage types navigators must provide information about.
Each year the Exchange must award at least one navigator grant to a community and consumer‑focused nonprofit organization.
The Secretary must obligate $100,000,000 per fiscal year from issuer user fees to fund navigator grants for federal Exchanges beginning FY2026, and those funds remain available until expended.
Navigators must maintain a physical presence in the State to offer in‑person assistance, and the statute permits navigators to carry out their duties at any time during the year (not only during open enrollment).
Section-by-Section Breakdown
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Selection criteria and community nonprofit floor for federal Exchanges
This provision directs federally‑operated Exchanges to award grants based on an entity’s demonstrated capacity to perform the duties set out in paragraph (3). It also bars the Exchange from considering whether an applicant will provide information about group health plans that are not qualified health plans when making awards. Practically, this shifts evaluation toward past performance and operational capability and away from requiring navigators to cover employer or other non‑QHP group products. The Exchange must also ensure at least one grant goes to a community and consumer‑focused nonprofit every year, establishing a minimum allocation for grassroots providers.
Expanded duties: Medicaid/CHIP, plain‑language education, year‑round authority
The bill adds State Medicaid and CHIP programs to the list of coverage types about which navigators must provide information. It inserts a new duty requiring public education activities in plain language focused on QHP requirements and protections. The amendment also clarifies that navigators may perform statutory duties at any time during the year—enabling outreach and assistance outside traditional open‑enrollment windows (important for special enrollments and Medicaid/CHIP transitions).
In‑state physical presence requirement
The bill adds an explicit clause that navigator entities must maintain physical presence in the State of the federally‑operated Exchange to allow in‑person consumer assistance. That creates an operational standard for grantees and could affect remote or multi‑state organizations that currently provide virtual‑only support; Exchanges will need to define what level of presence satisfies the requirement (office, regular clinic hours, or periodic outreach sites).
Dedicated federal exchange funding from issuer user fees
This amendment splits the funding subsection into state and federal exchange subsections and directs the Secretary to obligate $100 million annually from amounts collected through issuer user fees for federal exchanges starting in FY2026. The money is earmarked for carrying out the navigator program on federally‑operated Exchanges and remains available until expended—giving HHS multi‑year budget flexibility rather than a single fiscal‑year ceiling.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Community and consumer‑focused nonprofit organizations — the bill guarantees at least one annual grant recipient in this category, improving access to federal grant dollars for grassroots groups that typically do direct outreach.
- Low‑income and Medicaid/CHIP‑eligible consumers — navigators must now provide information about Medicaid and CHIP and conduct plain‑language public education, which should clarify eligibility and enrollment pathways.
- Federally‑operated Exchanges — the $100M annual obligation from issuer user fees provides a predictable funding stream for navigator programs on federal Exchanges, allowing longer‑term planning and program continuity.
- Consumers who prefer in‑person help — the physical presence requirement aims to expand availability of face‑to‑face assistance in states with federally‑run Exchanges.
- Navigator organizations with demonstrated capacity — selection criteria favor proven operational capability, benefiting established groups that can document outcomes and systems.
Who Bears the Cost
- Health insurance issuers participating in federal Exchanges — the funds come from existing user fees on issuers, which effectively increases the portion of those fees allocated to navigator grants and may indirectly affect issuers’ administrative budgets or premiums.
- Smaller or virtual‑first navigator organizations — the in‑state physical presence requirement and expanded duties could impose new overhead (office space, local staff) and compliance costs that challenge remote or lean providers.
- Federally‑operated Exchanges/HHS administrative units — although funding is provided, Exchanges must redesign grant processes, define presence standards, and expand oversight and reporting, generating administrative workload.
- State‑operated Exchanges and non‑federally‑operated programs — the bill creates a funding differential favoring federal Exchanges, which could widen resource disparities between state and federal platforms.
Key Issues
The Core Tension
The central dilemma is between expanding and stabilizing consumer assistance through guaranteed funding and community access on one hand, and imposing new operational and funding trade‑offs on the other: the bill improves outreach and funding predictability for federal Exchanges and community groups but does so by directing issuer fees, creating new location and performance requirements for navigators, and narrowing the scope of required counseling about non‑QHP group plans—choices that advantage some stakeholders while increasing burdens or reducing flexibility for others.
The bill threads several implementation puzzles into the navigator program. First, the in‑state physical presence requirement is operationally vague: the statute does not define the frequency, staffing level, or type of facility that satisfies 'physical presence,' leaving Exchanges to create standards that could vary widely by state.
That variance will affect which applicants can realistically apply and may privilege organizations that can afford permanent local offices. Second, directing $100 million per year from issuer user fees locks funding for federal Exchanges to a revenue stream that insurers ultimately fund; HHS must balance that obligation with other uses of fee revenue and consider whether issuers will seek to pass increased costs to consumers.
Third, prohibiting consideration of an applicant’s plan to provide information about non‑QHP group plans reduces a potential burden on navigators but can create practical gaps: many consumers compare employer offers with Marketplace plans, and navigators who are restricted from counseling on non‑QHP group coverage could leave customers without neutral comparisons. Finally, the guaranteed award to a community nonprofit introduces a minimum allocation that could affect competitive scoring and grant size for other applicants, raising questions about how Exchanges will balance equity goals against efficiency and demonstrated capacity in awarding limited funds.
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