You’ve probably heard about ACA health plans sold on the exchange, but ACA-compliant options also exist off the exchange — and understanding the distinction can help you guide your clients more effectively.
Below, you’ll find clear answers to the most common questions agents have about ACA plans, exchanges, and how these different coverage options work.
What’s the Difference Between On-Exchange and Off-Exchange?
ACA plans can be purchased two ways:
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On-exchange: Bought through the federal or state marketplace.
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Off-exchange: ACA-compliant plans purchased directly from an insurance carrier, without going through the marketplace.
Some states use their own state-run exchange instead of the federal platform, but the process is similar: you quote, compare, and enroll clients through the state’s system.
As explained by CMS, exchanges exist to make it easier for individuals and small businesses to compare health plan options based on cost, benefits, and quality.
How Do On-Exchange and Off-Exchange Plans Differ?
While both types of plans follow ACA rules, there are key differences:
Why choose an on-exchange plan?
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Only on-exchange plans offer federal subsidies and premium tax credits.
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Plan comparisons are straightforward and standardized.
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Metal tiers (bronze, silver, gold, platinum) are clearly defined.
Why choose an off-exchange plan?
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Carriers may offer additional plan choices not found on the exchange.
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Networks and pricing can differ from marketplace offerings.
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Some clients prefer paying out-of-pocket to keep specific doctors or hospitals.
Are Both Types of Plans Regulated the Same Way?
Yes. Both on- and off-exchange major medical plans must follow the same ACA rules and are required to include the 10 Essential Health Benefits, which include:
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Outpatient care
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Emergency services
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Hospitalization
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Maternity and newborn care
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Mental health/substance use treatment
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Prescription drugs
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Rehabilitative/habilitative services
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Lab tests
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Preventive and chronic disease services
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Pediatric services (including dental and vision)
While off-exchange plans don’t need to be certified as Qualified Health Plans (QHPs), many carriers still offer QHP options both on and off the exchange. QHPs must also cover pre-existing conditions, follow cost-sharing rules, and cannot impose annual or lifetime limits.
Both plan types follow the same Open Enrollment and Special Enrollment Period rules.
Can Agents Sell Both On- and Off-Exchange Plans?
Absolutely. Agents are allowed to sell both types of plans.
Some states require FFM or state marketplace certification to sell off-exchange plans — but not all. Still, obtaining your certification is recommended so you can assist clients with any ACA plan they’re eligible for.
Do Commissions Differ for On-Exchange vs. Off-Exchange Plans?
Compensation varies by carrier and state. While you’ll earn a commission for helping a client enroll in either type of plan, some carriers may pay differently for on- vs. off-exchange enrollments.
Always review each carrier’s commission schedule for accurate details.
Can a Client Receive ACA Subsidies with an Off-Exchange Plan?
No. Subsidies and premium tax credits are only available for plans purchased through the exchange.
If affordability is a priority, use a subsidy calculator to determine whether your client qualifies for financial assistance—they may be eligible for more savings than they expect.
How Do I Know If My Client Qualifies for Subsidies?
Eligibility for subsidies is based on income and household size. The IRS provides detailed guidelines on income requirements for premium tax credits.
Clients who receive subsidies must report them on their taxes each year. Make sure they understand the reporting requirements so they can file correctly.
What Is Enhanced Direct Enrollment (EDE)?
Enhanced Direct Enrollment allows consumers to enroll in on-exchange coverage without visiting HealthCare.gov.
Approved partners like HealthSherpa offer a fully integrated version of the federal application directly on their platform, letting clients complete the process quickly and securely. Although the consumer doesn’t use the federal website, they still access all the benefits and subsidies of marketplace enrollment.
EDE is currently available in FFM states and Georgia.
Agents can register with Essential Care on HealthSherpa using code 8ce251a0 to access enrollment tools, support, and lead-sharing opportunities.
What Are the ACA Metal Tiers?
Marketplace plans fall into four categories based on how costs are shared between the plan and the member:
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Bronze:
Covers about 60% of medical costs. Lowest monthly premiums, highest out-of-pocket costs. Best for people who rarely use healthcare services. -
Silver:
Pays around 70% of medical expenses. Moderate premiums and generally lower deductibles than bronze.
Note: Cost-sharing reductions (CSR) are only available with silver plans. -
Gold:
Covers roughly 80% of costs. Higher premiums but lower out-of-pocket costs. Ideal for clients who use medical services regularly. -
Platinum:
Covers approximately 90% of costs. Highest premiums, lowest out-of-pocket expenses.
Final Thoughts
The ACA marketplace can feel complex at first, but understanding the basics of on- and off-exchange plans will help you confidently guide your clients toward the right coverage.
If you have additional questions or want support with under-65 health plans, reach out to your sales specialist—we’re always here to help!
Not affiliated with or endorsed by Medicare or any government agency.
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