As the nation steadies after the seismic shock of the COVID‑19 pandemic, the health‑insurance marketplace remains a hybrid of emergency flexibilities and a cautious return to pre‑pandemic standards. At a press briefing in Washington, D.C., on Thursday, Lorena Granadillo de Fernandez, founder and chief executive officer of Mighty Shield Insurance, laid out how the crisis reshaped the ACA Marketplace, the lingering challenges that persist in 2025, and what she expects to see by 2026.

Granadillo de Fernandez, a Venezuelan‑born entrepreneur who entered the U.S. insurance industry in 2019, has built Mighty Shield into a nationally recognized agency that now serves more than 8,000 customers. Her agency has earned the Centers for Medicare & Medicaid Services (CMS) Circle of Champions Award every year since 2022, a testament to its enrollment volume and educational outreach. In the briefing, she turned that expertise toward a broader industry diagnosis and a forward‑looking forecast.

Pandemic‑Era Adjustments That Became Permanent Fixtures

“The pandemic forced us to re‑engineer the health‑insurance system in real time,” Granadillo de Fernandez told reporters. “Many of the changes we made were meant to be temporary, but they have now become embedded in how the Marketplace operates.”

She cited three structural shifts that were introduced during the 2020 health emergency and remain in place:

Expanded Application Flexibility – The ACA Marketplace loosened identity‑verification requirements, allowing applicants to be qualified without prior documentation and granting extended timeframes for confirmation. The Special Enrollment Period (SEP) temporarily stopped demanding proof of qualifying life events, enabling rapid coverage for those displaced by the pandemic.

Enhanced Premium Tax Credits (EPTC) – Enacted through the pandemic relief legislation, the EPTC broadened subsidy eligibility, permitting millions of beneficiaries to enroll in plans with $0 monthly premiums. The credit also decoupled from strict tax‑filing verification, letting individuals retain subsidies even without a prior‑year Form 1095‑A.

Relaxed Compliance Verification – Federal tax‑filing checks that previously underpinned premium‑tax‑credit eligibility were softened, reducing administrative burden for both consumers and insurers during an unprecedented public‑health crisis.

“These temporary measures made access to health coverage more flexible during the emergency,” Granadillo de Fernandez said, “but they also created long‑term challenges in restoring normal compliance and verification standards within the U.S. insurance system.”

The After‑Effects: A Hybrid Marketplace in 2025

Five years later, the ramifications of the pandemic‑era measures are still palpable. Granadillo de Fernandez noted that the EPTC and flexible enrollment rules have become difficult to reverse without causing major disruption for millions of insured Americans.

“The system now operates under a hybrid model where regulatory flexibility and economic support coexist with ongoing efforts to restore accountability and compliance,” she explained. “Agents, carriers, and agencies must work harder to re‑educate consumers about eligibility requirements, tax obligations, and the importance of maintaining accurate information within their Marketplace applications.”

Consumers, she added, have developed new expectations for affordability. “Many have become accustomed to $0‑premium plans and lenient verification processes,” Granadillo de Fernandez warned. “That expectation places financial and administrative pressure on carriers and regulators as they attempt to transition back to pre‑pandemic standards.”

Industry analysts echo her concerns. A recent report from the Kaiser Family Foundation indicates that over 30 % of ACA enrollees in 2024 still receive subsidies that exceed the statutory 100 % of the national average premium, a direct legacy of the EPTC. Meanwhile, the Department of Health and Human Services (HHS) has flagged a rise in enrollment errors, attributing them partly to the looser documentation standards that persisted after the emergency period.

Struggling to Re‑Balance Benefit Structures

Granadillo de Fernandez described the current struggle as a “delicate balance between restoring fiscal responsibility and protecting coverage stability.” As subsidies wind down, regulators risk a potential surge in premium costs for consumers who were previously shielded by the pandemic‑era credits.

“We are seeing a tension between affordability and sustainability,” she said. “If we pull back too quickly, we risk destabilizing the coverage that many families now rely on. If we delay, the system’s fiscal integrity could be compromised.”

She highlighted two specific pain points:

Enrollment Behavior Shifts – The pandemic’s leniency led to a spike in “spur‑of‑the‑moment” enrollments that often lacked complete eligibility verification. This has introduced a cohort of enrollees whose continued participation may not meet the standard ACA criteria, prompting calls for stricter oversight.

Compliance Overload – Carriers are now grappling with a dual burden: they must honor existing subsidies while implementing tighter verification protocols. The resulting administrative load has strained internal compliance teams and widened the gap between federal guidance and state‑level implementation.

2026 Forecast: Three Scenarios

When asked about the outlook for 2026, Granadillo de Fernandez presented three possible scenarios, each hinged on how policymakers, insurers, and the public respond to the lingering pandemic legacy.

Gradual Reconciliation – In this most optimistic scenario, Congress enacts a targeted extension of the EPTC for low‑ and middle‑income households while simultaneously tightening verification processes. This would preserve affordability for the most vulnerable while gradually restoring compliance standards. Granadillo de Fernandez believes this path is “the most responsible way to protect coverage without sacrificing system integrity.”

Abrupt Subsidy Withdrawal – A more aggressive approach could see Congress allowing the EPTC to phase out completely by mid‑2026, forcing many enrollees onto higher‑premium plans. The resultant premium spikes could spur a mass exodus from the Marketplace, pushing a wave of consumers back into the individual market or into uninsured status. Granadillo warned that “such a shock could destabilize the ACA’s risk pool and reverse the coverage gains of the past decade.”

Comprehensive Reform – The third possibility involves legislative reform that reshapes the ACA’s subsidy architecture—for example, moving toward a universal premium‑tax‑credit model that caps costs at a fixed percentage of income. While politically ambitious, this would eliminate the need for temporary emergency measures altogether. Granadillo expressed cautious optimism: “If we can design a system that guarantees affordability while preserving compliance, we could finally close the pandemic‑era gap.”

She stressed that the 2026 outcome will largely depend on the political climate and the willingness of federal and state regulators to cooperate. “Stakeholder collaboration—between insurers, agents, consumer advocates, and policymakers—will be the decisive factor,” she said.

Quality of Service: The Mighty Shield Playbook

Amid the systemic turbulence, Granadillo de Fernandez emphasized that quality of service remains non‑negotiable for her agency. “At Mighty Shield, quality is the foundation of everything we do,” she said.

Her agency’s approach includes:

Continuous Education – Agents receive monthly training modules that reflect the latest CMS regulations, Marketplace updates, and carrier‑specific guidelines. The curriculum stresses not only product knowledge but also ethical communication and transparent client interaction.

Robust Supervision – Mighty Shield employs a suite of real‑time monitoring tools and conducts quarterly performance reviews. Each enrollment is audited for compliance, and any deviation triggers immediate remedial coaching.

Compliance‑First Culture – The internal policy hierarchy prioritizes accuracy over volume. “We have instituted a ‘no‑go’ rule on any enrollment that lacks full verification, even if that means a slower sales cycle,” Granadillo explained. “Our agents are gatekeepers, and we empower them with the knowledge and authority to say ‘no’ when a case does not meet standards.”

The agency’s investment in education has paid dividends. According to Mighty Shield’s 2024 internal audit, compliance error rates are 40 % lower than the industry average, and customer‑satisfaction scores have risen to a record 4.8 out of 5 on the National Insurance Survey.

Granadillo’s philosophy of ethical education extends beyond her own network. Mighty Shield supports agents in founding sub‑agencies, providing mentorship and compliance frameworks that replicate the parent company’s standards. “We see ourselves as a catalyst for industry‑wide improvement,” she said. “If we can raise the bar for one hundred agents, that ripple effect can influence thousands more.”

A Vision for the Future of US Healthcare

Granadillo de Fernandez offers a concise summation of her outlook: “The pandemic taught us that flexibility can be a lifesaver, but it also reminded us that a system built on sound verification and fiscal responsibility is essential for lasting health security.”

She urged policymakers to adopt a balanced, data‑driven approach, recommending incremental subsidy adjustments that protect low‑income families while encouraging market stability, as well as standardized verification protocols across states to reduce enrollment errors and increased funding for agent education, recognizing agents as the frontline educators who translate policy into personal coverage decisions.

For the millions of Americans who rely on the ACA Marketplace and Medicare, the stakes are high. As Granadillo de Fernandez and industry peers navigate the post‑pandemic landscape, the 2026 crossroads may determine whether the United States can sustain the coverage expansions achieved during the crisis without compromising the system’s long‑term viability.

Visit mightyshieldinsurance.com for more information.

Published on October 16, 2025.