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Low Income SEP: Members at or below 150% FPL will no longer have the ability to change plans and/or issuers monthly, across all Exchanges. Members will need to enroll during the annual OEP and could make a plan change during the plan year if they experience a qualifying life event, which gives them a SEP. Note: this does not impact the monthly SEP for members of federally recognized tribes.
Income Verification When Data Sources Indicate Household Income Less than 100% of the FPL: All Exchanges are required to generate annual income Data Matching Issues (DMIs) in circumstances when applicants report a household income above 100% FPL, but federal data sources show annual income less than 100% FPL. This policy will conclude on Dec. 31, 2026.
Income Verification When Tax Data is Unavailable: Exchanges can no longer accept a consumer’s self-attestation of projected annual household income when the IRS cannot verify because there is no tax data available. Instead, Exchanges must verify household income using other trusted data sources and follow the full alternative verification process. This policy will conclude on Dec. 31, 2026.
60-Day Extension to Resolve DMIs: The automatic 60-day extension has been removed for members to resolve a DMI(s). Consumers can still request a 60-day extension if they demonstrate that a good faith effort has been made to obtain the required documentation during the 90-day period.
Affirming Previous Interpretation of “Lawfully Present” Definition (Deferred Action for Childhood Arrivals-DACA): DACA recipients are excluded from the definition of "lawfully present" for purposes of QHP enrollment, APTC and CSR eligibility, and Basic Health Program coverage.
Please note: CMS will notify impacted households currently enrolled in 2025 Marketplace coverage. Impacted members are allowed to apply for off-exchange coverage.
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