Sources reviewed: October 7, 2026
A Marketplace data matching issue can leave a client worried about losing financial help or health coverage. The agent’s first job is to identify the exact fact the Marketplace needs to verify, then connect the right evidence to the right person, application, and deadline.
For 2027, that work also requires checking current implementation guidance and distinguishing a verification problem from a change in eligibility. Financial help includes advance payments of the premium tax credit, or APTC, and cost-sharing reductions, or CSR, when eligible.
This guide uses HealthCare.gov and the federal Marketplace platform as its operational baseline. For a state Marketplace, confirm its notices, document process, and appeal instructions. The workflows and case-management suggestions below are recommended agency practices unless a specific requirement is identified.
1. What changed for 2027—and what agents should do
| Topic | Current position as of October 7, 2026 | Practical response |
|---|---|---|
| Income DMI extension | CMS reimplemented the automatic additional 60 days for household-income inconsistencies. | Track the initial deadline and applicable extension. Confirm any conflicting notice promptly. |
| Additional income checks in the 2027 final rule | The provisions concerning data below 100% of the federal poverty level and removal of the requirement to accept income attestation when IRS data are unavailable are stayed. | Avoid presenting those provisions as active new blanket document requirements. Respond to actual verification requests. |
| Failure to file and reconcile, or FTR | CMS directs Exchanges to stop denying or removing APTC because of prior FTR for 2026 and 2027. Earlier two-year FTR guidance is no longer valid. Tax filing and reconciliation obligations remain. | Separate a Marketplace eligibility problem from the client’s outstanding tax work. |
| Immigration status and financial help | Beginning January 1, 2027, eligibility for federal savings is narrower for noncitizens. Some people may qualify to buy coverage without qualifying for savings. | Check enrollment eligibility and financial-assistance eligibility separately. See Section 7. |
These positions reflect CMS’s July 27 and August 4 implementation statements and HealthCare.gov’s 2027 immigration guidance. Keep the review date visible: a final-rule summary may describe provisions affected by later litigation. cms.gov
2. Identify the problem before collecting documents
A DMI means information on an application cannot be confirmed against available records. A request for documents does not necessarily mean the consumer entered something incorrectly. Income may have changed, a record may be outdated, or a name or document number may need correction. HealthCare.gov
Use this diagnostic table before deciding what to upload:
| Issue | Question to answer | First action |
|---|---|---|
| Income DMI | What annual household income is reasonably expected for the coverage year? | Review the estimate, periods, and supporting records. |
| Citizenship, immigration, or SSN inconsistency | Which identifying fact or status cannot be verified? | Compare the notice, application entry, and relevant document. |
| Other-coverage DMI | Does the person have, or qualify for, coverage that affects Marketplace financial help? | Identify the program or employer offer and relevant dates. |
| SEP verification issue | What event permits enrollment outside Open Enrollment? | Establish the event and required supporting facts. |
| Account identity proofing | Has the account user’s identity been verified? | Use the identity-proofing process identified by the platform. |
| Periodic data matching notice | Does a later records check indicate other coverage or a changed eligibility fact? | Follow that notice’s response instructions and deadline. |
| FTR-related notice | Is this about prior tax filing and Form 8962 reconciliation? | Check current CMS implementation guidance and identify the remaining tax task. |
| A change in substantive eligibility | Are the facts correct, but the applicable eligibility rules different? | Review the eligibility category and decision rather than repeatedly submitting the same evidence. |
HealthCare.gov provides separate upload paths for application inconsistencies, identity proofing, and SEP confirmation. Periodic data matching also has its own notice and response procedures. Treat each open request as its own task. HealthCare.gov
A document’s usefulness depends on what it proves. An ordinary wage-only pay stub may not establish when health coverage ended. However, HealthCare.gov accepts certain paired pay stubs showing that insurance deductions stopped as evidence of coverage loss. Avoid blanket rules that a particular document can never serve more than one purpose. www.healthcare.gov
Can the client enroll while a DMI is pending?
If the eligibility notice says the consumer can buy a Marketplace plan, HealthCare.gov says enrollment can proceed while requested DMI information is outstanding. The issue still needs resolution to protect eligibility. Track any required first premium separately and confirm policy status with the insurer. HealthCare.gov
Requested SEP verification follows a different process and can affect when coverage may be used. Check for both requests on the application. www.healthcare.gov
3. Track the right deadline
| Request | Deadline framework | What belongs in the case record |
|---|---|---|
| Household-income DMI | Standard 90-day period, plus the restored automatic 60-day extension where applicable—generally 150 days total. | Initial notice date, initial deadline, and applicable extended deadline. |
| Citizenship or lawful-presence DMI | Generally 95 days. | Exact deadline in the notice; do not add the income extension. |
| SSN mismatch or deceased indicator | The regulation provides 90 days after receipt, with receipt ordinarily presumed five days after the notice date. | Specific notice and applicable receipt date. |
| Other ordinary inconsistencies | Generally 90 days from when the notice is sent, subject to the applicable rule. | Issue type and notice deadline. |
| 2027 eligible-noncitizen financial-assistance verification | Follow the specific notice and applicable verification instructions. | Identify whether enrollment, financial help, or both are affected. |
| Requested loss-of-coverage SEP proof | Generally 30 days after plan selection on HealthCare.gov. | Document deadline separately from the enrollment window. |
| Marketplace eligibility appeal | Generally 90 days from the Eligibility Notice. | Appeal deadline separately from document follow-up. |
The income period and restored extension are explained across different sources: HealthCare.gov lists the base period, while CMS’s later statement restores the additional time. The regulations address the distinct receipt rules and eligible-noncitizen verification process. HealthCare.gov SEP document deadlines and appeal deadlines follow their own instructions. www.healthcare.gov
If the account or notice appears inconsistent, contact the Marketplace rather than assuming a date or disregarding the request.
An Exchange may also grant an extension when the applicant demonstrates good-faith efforts to obtain documents. That is a separate, case-specific provision. Record requests for replacement records and ask before the deadline; approval and additional time are not guaranteed. ecfr.gov
Recommended agency practice: act early even when an extension applies. Set reminders before the controlling deadline and assign a named owner. An extension provides time to resolve a problem; it should not become the target date for starting work.
4. Open the case with a notice review and an application check
Before requesting a stack of documents, create a short case record:
- Marketplace and coverage year. A 2026 application and a 2027 renewal may have different requests.
- Application ID and affected person. Match the ID to the notice, then identify each household member with an issue.
- Exact request and dates. Save the full notice, including document instructions and any barcode page.
- Information currently reported. Record the disputed income, status, other-coverage fact, or identifying entry.
- Consumer’s current facts. Ask what changed and what evidence exists.
- Next action, owner, and follow-up date. Make the next step specific enough for another team member to complete.
HealthCare.gov identifies the relevant requests through the eligibility notice and application details. Use the actual request to define the evidence needed. HealthCare.gov
If the application is wrong, correct it with the consumer’s review. If the application is accurate but older records differ, explain the difference. Changing a reasonable current estimate merely to match a historical record can create another inaccurate application.
For federal-platform assistance, document consumer consent before assisting, and document the consumer’s review and confirmation of application information before submission. The federal rule requires retention of those consent and review records for at least 10 years. Keeping related DMI evidence alongside them is a useful agency practice; do not describe every DMI document as independently subject to that same requirement without checking the applicable rule. www.ecfr.gov
CMS’s September 22, 2026 anti-fraud announcement also says agent-assisted applications must include verifiable SSNs or immigration document numbers for non-newborn applicants. It announces electronic consumer authorization planned ahead of Open Enrollment. Check the platform’s current instructions rather than treating the announcement as proof that every new screen is already live. www.cms.gov
5. Resolve an income DMI using the correct year’s projection
Marketplace savings depend on expected household income for the year of coverage. For 2027 coverage, the central question is what the household reasonably expects to receive during 2027. A prior return supplies evidence; it does not automatically determine the new year’s estimate. HealthCare.gov
Prepare a simple projection:
| Person or source | Expected period | Calculation | Evidence or assumption |
|---|---|---|---|
| Wages | Start and end dates | Expected taxable pay over that period | Pay stubs, employer information, known schedule |
| Self-employment | Business period | Expected receipts less business expenses | Ledger, contracts, recent results, expected changes |
| Other countable income | Expected payment period | Amount and frequency | Relevant benefit or payment records |
The following examples are illustrative. They show estimation methods, not a determination of subsidy eligibility.
Example A: A new job changes the 2027 estimate
A prior return shows $72,000. The client now expects taxable wages of $3,000 per month throughout 2027, with no other countable household income or adjustments in this simplified example.
2027 estimate: $3,000 × 12 = $36,000.
The file should explain the job change and show the evidence supporting the new wages. A short employer statement or current pay records can make the estimate understandable.
Do not add 2026 earnings to the 2027 total. Those earnings may help explain the trend, but they belong to a different coverage year.
Example B: A midyear job loss requires a full-year estimate
In July 2027, a client loses a job. Assume the client earned $18,000 earlier in 2027, expects $6,000 in unemployment compensation, and reasonably expects $9,000 from later work.
2027 estimate: $18,000 + $6,000 + $9,000 = $33,000.
Current monthly wages may be zero while the annual estimate remains positive. If the anticipated later work becomes unlikely, revisit the estimate instead of leaving an unsupported assumption in the file.
Example C: Seasonal income needs more than one paycheck
A client reasonably expects $6,000 per month for four busy months and $2,000 per month for eight slower months.
Annual estimate: ($6,000 × 4) + ($2,000 × 8) = $40,000.
Multiplying the busiest month’s pay by 12 would overstate this projection. Explain the seasonal schedule and the basis for expecting it to continue.
Self-employment: use net income
HealthCare.gov directs self-employed applicants to estimate net income and accepts an accurate, detailed ledger without requiring a standard format. HealthCare.gov
For example, $80,000 of expected business receipts minus $25,000 of business expenses yields $55,000 of projected business net income. Other countable household income and applicable MAGI adjustments still need separate consideration.
For an agency worksheet, record the business period, receipts, expense categories, net result, and any expected change. Keep the basis for the estimate visible instead of supplying an unexplained annual number.
Check what counts as income
Marketplace household income is based on modified adjusted gross income, or MAGI. Tax-household rules matter, including whether a dependent is required to file a federal return. Voluntarily filing only to obtain a refund does not automatically make the dependent’s income count. HealthCare.gov
Accepted evidence is not a list of countable income. Gifts, loan proceeds, SSI, child support, and workers’ compensation generally do not count under HealthCare.gov’s income instructions. Do not turn every bank deposit into Marketplace income merely because a record appears on a document list. HealthCare.gov
When an unusual payment, settlement, retirement transaction, or business distribution is material to the estimate, identify its tax treatment before finalizing the number. Obtain appropriate tax guidance when needed.
When to use the official income explanation form
HealthCare.gov’s Annual Income Letter of Explanation is available when annual-income verification is requested and the consumer lacks the other acceptable documents. It asks for the household estimate and year, identifying information, and application ID. The income must agree with the application; if the true estimate changed, update the application. healthcare.gov
An accompanying explanation can use this structure:
Coverage year: [year]
Expected annual household income: [amount]
Basis: [income sources, periods, and calculation]
Why older records differ: [job change, reduced hours, business change, or other facts]
Supporting records: [documents included or requested]
This is a suggested explanatory note, not a substitute for a requested official form or a guarantee of acceptance. Have the consumer confirm its accuracy. Follow the document-type option shown in the current upload screen.
Official form: Annual Income Letter of Explanation
Explain the repayment consequence accurately
For tax years after 2025, income-based repayment caps for excess APTC no longer apply. If advance credits exceed the final allowable credit, the full excess must be repaid. This affects 2026 coverage reconciled on a return filed in 2027, as well as 2027 coverage. It does not mean every enrollee must repay all subsidies. Internal Revenue Service
Encourage prompt updates when income or household facts change. Consumers can elect to use less than the full available credit in advance; explain that option when estimates are uncertain.
For outstanding reconciliation work, the consumer uses Form 1095-A information to complete Form 8962 with the federal tax return. An income-DMI upload does not complete that tax task. Internal Revenue Service
6. Match the document to the requested fact
Use the live Marketplace document list and the client’s notice. This table is a preparation aid, not an exhaustive list or an acceptance guarantee.
| Issue | Evidence to consider | Agent review before submission |
|---|---|---|
| Wages | Current pay records or relevant employer documentation | Name, pay period, amount, and whether the record supports the annual projection. |
| Self-employment | Ledger or profit-and-loss information | Covered dates and net result; explain expected changes. |
| Citizenship | U.S. passport or qualifying citizenship/naturalization certificate; otherwise the permitted citizenship-plus-identity combination | A birth certificate generally needs separate identity evidence. An ordinary driver’s license alone does not establish citizenship. |
| Immigration status | Applicable immigration documents from the official list | Check document type, identifying numbers, and the status being verified. |
| SSN | Documentation specified by the request and official list | Compare the name, birth date, and number to the application; use the supported correction process. |
| Employer coverage | Employer Coverage Tool or other accepted employer evidence | Check the offer, dates, employee/family cost information requested, and minimum-value information. |
| Medicaid, CHIP, Medicare, or other coverage | Relevant program notice or accepted coverage evidence | Establish the affected person, program, dates, and whether the notice concerns eligibility, enrollment, or termination. |
Document examples and acceptable combinations are listed by HealthCare.gov. Federal verification rules separately address employer and other minimum-essential-coverage eligibility. HealthCare.gov
For a household with several requests, write a short document-to-issue map: which record supports which fact for which person? A complete packet answers the request clearly; its usefulness does not depend on having the most pages.
Official document list: Documents to resolve a Marketplace inconsistency
7. Treat immigration verification and subsidy eligibility as separate questions
Beginning January 1, 2027, HealthCare.gov identifies three noncitizen categories eligible for federal Marketplace savings: lawful permanent residents, Cuban or Haitian entrants, and Compact of Free Association migrants, subject to other eligibility requirements. Other immigration statuses may still qualify for Marketplace coverage without savings. U.S. citizens and nationals remain subject to their ordinary eligibility rules. HealthCare.gov
The 2027 verification regulation distinguishes eligible-noncitizen status for financial assistance from the broader question of lawful presence for enrollment. An unresolved financial-assistance status issue can result in loss of APTC and cost-sharing reductions; that conclusion does not automatically mean the person is ineligible to buy a Marketplace plan. ecfr.gov
Use this three-question review:
- Was the document and identifying information matched correctly?
- What status does the evidence establish?
- What does that status permit for the coverage year—enrollment, financial help, or both?
An employment authorization card is a document type. Its existence alone does not answer whether the person falls within a category eligible for 2027 financial help. That is a practical consequence of the separate standards above. HealthCare.gov
If a client says, “You accepted my card, so why did my subsidy change?”, compare the actual eligibility decision with the applicable status. Repeated uploads cannot change a correctly applied eligibility rule. If the underlying status or decision is wrong, identify that specific error for correction or review.
8. Upload a readable packet to the correct request
On HealthCare.gov, select the application matching the notice’s application ID, open Application details, and upload against the specific issue. Repeat for other open requests. A successful-upload checkmark confirms the upload; it is not a final eligibility decision. HealthCare.gov
Before uploading, review the file as a reader would:
- Are the relevant names, dates, amounts, and document numbers legible?
- Are any required pages or document sides missing?
- Does the evidence correspond to the affected person and coverage year?
- If figures differ, does the explanation make the difference understandable?
- Is the file being attached to the right issue rather than simply somewhere in the account?
HealthCare.gov accepts specified formats, including PDF, JPEG, and PNG, with files under 10 MB. Use filenames without special characters. For ordinary DMI submissions, use the supported online upload or mail process; HealthCare.gov does not accept those documents by email or fax. Mail copies, not originals, with the required barcode page or identifying information. HealthCare.gov
As an agency practice, collect and store documents through an approved secure process. Avoid putting SSNs, immigration numbers, or other sensitive identifiers in filenames or ordinary task descriptions. Save the submission date and receipt with the case.
9. Follow up until there is a documented outcome
An upload, a review, an accepted document, and a final eligibility decision are different milestones. Track them separately.
| Case status | What it means | Next action |
|---|---|---|
| Evidence requested | The client or another source still needs to provide information. | Identify the missing item and due date. |
| Submitted; receipt unconfirmed | The packet was sent, but receipt is not established. | Verify delivery or successful upload. |
| Received; review pending | The Marketplace has the documents. | Track the deadline and watch for the decision. |
| More information required | The evidence did not finish the review. | Record the specific deficiency and respond. |
| Escalation or appeal pending | A further review has been requested. | Keep an owner, next action, and follow-up date. |
| Resolved | The Marketplace confirms resolution and resulting eligibility is recorded. | Explain the outcome and any enrollment or payment action. |
| Adverse decision; next steps documented | An unfavorable decision has been explained and the correction, appeal, or handoff is recorded. | Keep any pending action open; distinguish this outcome from a resolved DMI. |
HealthCare.gov advises calling if more than a month passes without a response. If receipt has been confirmed, it says not to upload identical documents again unless more information is requested. HealthCare.gov
That one-month guidance is not a requirement to wait when a deadline is approaching, receipt is uncertain, or coverage or financial help is at risk. Set an earlier follow-up when the case needs it.
Questions for a Marketplace call
Marketplace Call Center: 1-800-318-2596.
TTY: 1-855-889-4325. HealthCare.gov
With the consumer involved or appropriate authorization in place, ask:
“For application [ID], coverage year [year], and household member [name], can you confirm which verification issue remains open and whether the documents sent on [date] were received? What specific fact still needs verification? What deadline applies, including any applicable income extension? What should happen next, and is there a case or escalation reference?”
Record the answer, date, reference number, and next action. If the response is only “documents received,” keep the case in review-pending status.
Consumer update:
“The documents were received, and the Marketplace is reviewing them. I will check the outcome again on [date]. Please send us any new Marketplace notice promptly.”
10. If the deadline passed or eligibility changed
HealthCare.gov says to submit requested documents even after the deadline because the consumer may requalify for savings or coverage. Late submission does not guarantee automatic reinstatement or a retroactive effective date. HealthCare.gov
Ask these questions separately:
- Has the inconsistency been resolved?
- Has the Marketplace issued a new eligibility determination?
- What financial help is available, and from what effective date?
- Is the insurance policy active, or is additional enrollment action required?
- Does an earlier period require a correction request or appeal?
Do not describe “document accepted” as proof that a prior coverage gap has been filled. Eligibility changes have their own effective-date rules, and appeal decisions may specify a different result. ecfr.gov
Preserve appeal rights while pursuing document resolution
Marketplace eligibility appeals generally have a 90-day deadline from the Eligibility Notice. HealthCare.gov recommends submitting requested documents first because a new decision may resolve the issue. Track the appeal deadline while doing that; do not assume a document submission or pending telephone escalation extends it. HealthCare.gov
Use the correct route. Marketplace eligibility, financial-help, SEP, and coverage-start-date decisions can be appealable. Carrier claims, incorrect application of a tax credit by the insurer, and requests to change application facts have different processes. HealthCare.gov also excludes the Marketplace’s coverage-termination date itself from this eligibility-appeal route. HealthCare.gov
Continued coverage or savings during an appeal depends on the applicable determination. If eligible, maintain enrollment and premium payments. HealthCare.gov warns that credits received during an unsuccessful appeal must be repaid. An expedited appeal may be requested when ordinary processing would seriously threaten health. HealthCare.gov
Appeal instructions: How to file a Marketplace appeal
11. Printable DMI case worksheet
Use one issue record for each affected person and request, linked to the same household file where appropriate.
| Field | Record |
|---|---|
| Marketplace / coverage year | __________________________________ |
| Application ID / affected person | __________________________________ |
| Issue and fact needing verification | __________________________________ |
| Notice date / initial deadline | __________________________________ |
| Applicable extension / confirmed deadline / source | __________________________________ |
| Application fact checked or corrected | __________________________________ |
| Income projection and basis, if applicable | __________________________________ |
| Evidence requested / evidence submitted | __________________________________ |
| Submission date / receipt / reference | __________________________________ |
| Additional information or escalation needed | __________________________________ |
| Appeal deadline, if applicable | __________________________________ |
| Owner / next action / follow-up date | __________________________________ |
| Final determination / effective date / client notified | __________________________________ |
Before closing the issue
- The affected person, application, and coverage year match the notice.
- Each requested fact has a documented response or disposition.
- The Marketplace outcome is recorded, not merely the upload confirmation.
- The resulting coverage and financial-help status have been explained.
- Any enrollment, premium, correction, or appeal task has an owner.
- Pending actions remain open, even if document collection is complete.
- The client received clear next steps and knows to forward new notices.
An agency can close an administrative file after a documented final disposition or completed handoff. It should label that outcome accurately and avoid marking an unresolved appeal as “DMI resolved.”
12. Keep the record usable for the next person who touches the case
A useful DMI file connects the notice, consumer’s facts, evidence, submission, Marketplace response, and next action. That makes a renewal review, service call, or staff handoff easier to complete without asking the consumer to reconstruct the entire history.
Informed + Choice’s ACA workspace supports organizing consent, application-review records, Marketplace documents, and supporting evidence for retrieval and export. Use that recordkeeping capability to keep the case understandable while following the Marketplace’s actual verification and submission process. informedpluschoice.com
Explore the Informed + Choice ACA workspace
Related agent guides
Sources
- FTR requirement for plan years 2026 and 2027 : Centers for Medicare & Medicaid Services Accessed 2026-10-07.
- When the Marketplace needs more information : HealthCare.gov Accessed 2026-10-07.
- How to upload documents : HealthCare.gov Accessed 2026-10-07.
- Documents to prove loss of coverage : HealthCare.gov Accessed 2026-10-07.
- Confirm a Special Enrollment Period : HealthCare.gov Accessed 2026-10-07.
- Documents and deadlines : HealthCare.gov Accessed 2026-10-07.
- Verification of eligibility for enrollment in a QHP : Electronic Code of Federal Regulations Accessed 2026-10-07.
- Agent and broker consumer consent and application review : Electronic Code of Federal Regulations Accessed 2026-10-07.
- Federal Marketplace anti-fraud actions : Centers for Medicare & Medicaid Services Accessed 2026-10-07.
- What income to include : HealthCare.gov Accessed 2026-10-07.
- Reporting self-employment income : HealthCare.gov Accessed 2026-10-07.
- Annual Income Letter of Explanation : HealthCare.gov Accessed 2026-10-07.
- Questions and answers on the Premium Tax Credit : Internal Revenue Service Accessed 2026-10-07.
- Documents to resolve a Marketplace inconsistency : HealthCare.gov Accessed 2026-10-07.
- Immigration status and Marketplace eligibility : HealthCare.gov Accessed 2026-10-07.
- Verification of eligibility for financial assistance : Electronic Code of Federal Regulations Accessed 2026-10-07.
- After documents are submitted : HealthCare.gov Accessed 2026-10-07.
- Marketplace contact information : HealthCare.gov Accessed 2026-10-07.
- Eligibility redetermination during a benefit year : Electronic Code of Federal Regulations Accessed 2026-10-07.
- Marketplace eligibility appeals : HealthCare.gov Accessed 2026-10-07.
- Marketplace appeal instructions : HealthCare.gov Accessed 2026-10-07.
- Informed + Choice ACA workspace : Informed + Choice Accessed 2026-10-07.
Medicare and ACA Compliance Expert
Christian Rodgers is a Medicare and ACA compliance expert with over 30 years in the healthcare industry, having worked for some of the largest health plans in the United States. He has provided Medicare sales training to hundreds of agents in California and Florida.
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