People applying for Marketplace financial assistance would have to resolve certain discrepancies in their eligibility information before an Exchange could authorize that assistance, under a CMS proposal scheduled to be published in the Federal Register on October 27.
The proposal would change when advance premium tax credits and cost-sharing reductions can begin for 2028 coverage and later years. It is not a final rule and does not impose a new application requirement today.
Which information would need verification
CMS proposes withholding those payments while specified data matching issues remain unresolved. A data matching issue is a discrepancy between application information and the records used to check it, or a case where verification data are unavailable.
The listed issues concern citizenship or lawful presence, residency, other qualifying health coverage, annual household income, family size and eligible noncitizen status. The proposal includes exceptions, including specified special enrollment periods involving changes in family size. Applicants whose data matching issues concern only other information would continue to receive assistance during the inconsistency period when otherwise eligible.
The agency describes the proposal as implementing eligibility-verification requirements in legislation enacted in July 2025.
Annual confirmation and an earlier start
For the following year's assistance, CMS would require an enrollee or application filer to provide or confirm specified information between August 1 and December 31. Exchanges would have to verify it using the specified processes, including the procedures for inconsistencies.
The proposal would establish an optional period for consumers to provide information before open enrollment begins, starting August 1, 2027, for 2028 coverage. Exchanges would be required to offer that period.
Applicants could also choose to hold a plan selection until the Exchange determines eligibility for assistance. CMS proposes rules governing when coverage and assistance would then start; submitting documents would not by itself establish immediate eligibility or a universal retroactive start date.
How to comment
The inspection copy prints its deadline as "[INSERT DATE 30 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER]". Assuming publication occurs as scheduled, the deadline is November 27 by this desk's count, including the Federal-business-day rollover used by the daily inspection-date instrument.
The document directs electronic comments to docket CMS-2026-3367 and asks commenters to identify file code CMS-9873-P. CMS says public comments may include any personal or confidential information submitted, so applicants should not treat the public docket as an individual case-resolution channel.