ACA Marketplace Data Matching Issues: A Practical 2027 Field Guide for Agents

A Marketplace data matching issue is not primarily a quoting problem. It is a deadline, documentation, and follow-up problem.

A client may have already selected a plan. The premium may look correct. The application may appear complete. But if the Marketplace cannot verify income, citizenship, immigration status, or another eligibility fact, the client may later lose premium tax credits, cost-sharing reductions, or even eligibility for Marketplace coverage.

For agents, the work is not finished when a document is uploaded.

The file is finished when the correct issue has been identified, the application information has been reconciled with the client, acceptable evidence has been submitted under the correct household member and application, receipt has been confirmed, and the Marketplace has issued a determination showing that the issue is resolved.

Quick answer for ACA agents

A data matching issue, sometimes called a DMI or inconsistency, occurs when information on a Marketplace application differs from information available through a trusted data source.

When a client receives a DMI, the agent should:

1. obtain the actual Marketplace notice;
2. identify the affected household member, issue, application ID, and deadline;
3. verify whether the application information is still accurate;
4. correct the application if the underlying facts are wrong or have changed;
5. gather documents that support the current application information;
6. upload each document under the correct issue;
7. preserve proof of the upload and related client authorization;
8. track the case until the Marketplace issues a new notice or otherwise confirms resolution.

HealthCare.gov generally gives consumers 90 days to verify information such as household income, 95 days to verify citizenship or immigration status, and 30 days to provide requested Special Enrollment Period documentation. The deadline in the client’s actual notice controls.

Reviewed August 18, 2026

This guide focuses primarily on agents assisting consumers through HealthCare.gov, Federally-facilitated Marketplaces, and State-based Marketplaces using the federal platform. A State-based Marketplace operating its own platform may use different notices, deadlines, document lists, and upload procedures.

This article is agent education, not legal, tax, immigration, Marketplace, carrier, or state-specific advice. Always follow the client’s current eligibility notice, current CMS and Marketplace instructions, applicable state requirements, carrier and agency procedures, and qualified professional advice where appropriate.

Important 2027 status update: not every finalized verification change is currently in effect

CMS’s 2027 Payment Notice final rule included two changes especially relevant to this subject:

• broader income verification when trusted data indicates income below 100% of the federal poverty level or when IRS tax data is unavailable; and
• broader pre-enrollment verification of Special Enrollment Periods on Exchanges using the federal platform, including a requirement to verify at least 75% of new SEP enrollments.

CMS published the final rule in May 2026 and initially stated that it would become effective July 20, 2026. (CMS 2027 Payment Notice final-rule fact sheet)

However, on July 16, 2026, the U.S. District Court for the District of Maryland granted a stay preventing several challenged provisions from taking effect. The stayed provisions included the heightened income-verification provisions and the broader SEP-verification provision. The court described the current federal-platform regulation as requiring pre-enrollment verification for a loss-of-minimum-essential-coverage SEP, while the stayed rule would have expanded mandatory verification to additional SEP categories and at least 75% of new SEP enrollments. (City of Columbus v. Kennedy, July 16, 2026 memorandum opinion)

The stay is a preliminary court action, not a final resolution of the litigation. Its status may change.

Practical agent takeaway

Do not tell clients or downline agents that the 2027 rule’s broader income and 75% SEP-verification provisions are unquestionably operative.

Instead:

• follow the document request displayed in the client’s actual Marketplace application;
• follow the deadline in the current eligibility notice;
• use current HealthCare.gov and CMS operational instructions;
• maintain a document-ready workflow even when verification is not automatically required; and
• update agency training when CMS or the court provides new instructions.

The rest of this guide addresses the data matching and document-resolution process agents encounter in live Marketplace files today.

What is a Marketplace data matching issue?

HealthCare.gov defines a data matching issue as a difference between information entered on a Marketplace application and information available from other trusted data sources. The Marketplace may request documents concerning income, citizenship, immigration status, eligibility for other health coverage, or another application fact. (HealthCare.gov DMI definition)

The Marketplace may compare application information with records from sources that include:

• the Social Security Administration for Social Security numbers and citizenship;
• the Department of Homeland Security for immigration status or naturalized citizenship;
• the Internal Revenue Service for household income and family-size information;
• the Social Security Administration for certain income information; and
• a consumer reporting agency for certain income verification. (How HealthCare.gov uses application data)

A mismatch does not, by itself, explain why the records differ.

The client may have:

• started a new job;
• lost a job;
• changed from hourly work to self-employment;
• received irregular commissions;
• changed a legal name;
• recently become a citizen;
• renewed or replaced an immigration document;
• entered a document number incorrectly;
• been assigned income from an outdated source;
• submitted an application before another government system was updated; or
• made a genuine mistake on the application.

That is why the agent should not begin by assuming either the application or the government data is correct.

Start with the notice and the current facts.

DMI, SEP verification, identity proofing, and periodic data matching are not the same thing

Agents often use “verification issue” as a catch-all term. Operationally, that creates mistakes.

CMS maintains separate agent resources for annual income DMIs, SEP verification issues, and Marketplace periodic data matching. Its Video Learning Center also contains separate walkthroughs for resolving a DMI and resolving a SEP verification issue.

Why the distinction matters

An income DMI is not resolved by uploading a marriage certificate.

A loss-of-coverage SEP issue is not resolved by uploading a pay stub.

An identity-proofing document should not be uploaded under an annual-income inconsistency.

The same client can also have more than one open issue at the same time. An application may show:

• an income DMI for the tax filer;
• a citizenship DMI for one dependent;
• an immigration DMI for another applicant; and
• a SEP verification request for the qualifying event.

Each issue needs to be handled separately.

Marketplace document deadlines for agents

The actual notice is the controlling source, but HealthCare.gov currently lists these general timeframes:

A household may have different deadlines for different people or issues. Do not place one general “DMI due date” in the CRM and assume it applies to the entire application.

Build the deadline record from the notice

Record:

• date of the notice;
• application ID;
• coverage year;
• affected household member;
• exact issue description;
• exact document deadline;
• documents listed as acceptable;
• date the client was contacted;
• date documents were received;
• date and method of upload;
• next follow-up date;
• current Marketplace status; and
• final resolution date.

The practical ACA agent workflow for resolving a DMI

Step 1: Confirm authorization before accessing or changing the file

Before accessing Marketplace information, collecting documents, updating an application, or discussing personally identifiable information, confirm that the agent or agency has current, documented consumer consent for the work being performed.

If the application must be corrected or resubmitted, document the consumer’s review and confirmation of the revised application information before submission.

Consumer consent and eligibility application review are separate records. The companion guide, ACA Consumer Consent vs. Application Review, explains the timing and required documentation.

Step 2: Get the actual notice

Do not troubleshoot a DMI from the client’s memory alone.

Clients commonly say:

• “They need my taxes.”
• “My subsidy was denied.”
• “They need proof that I’m legal.”
• “The application is asking for documents.”
• “I already sent that.”
• “My insurance company says I have a deadline.”

Those statements are not specific enough.

Have the consumer retrieve the eligibility notice from the Messages section of the Marketplace account, or review the action items under Application details. HealthCare.gov says the notice identifies the information that must be confirmed and the applicable deadline.

Identify:

1. Which application?
2. Which coverage year?
3. Which household member?
4. Which issue?
5. What information did the consumer report?
6. What evidence is requested?
7. What is the exact due date?
8. Is this a DMI, SEP verification issue, identity issue, or another notice?

Step 3: Reconcile the facts before collecting documents

A document should support the application. It should not be used to avoid correcting an inaccurate application.

Ask:

• Is the income on the application still the client’s best projection?
• Did the client change jobs after applying?
• Did employment end?
• Is the person self-employed?
• Was gross business revenue entered instead of net self-employment income?
• Was a former employer left on the application?
• Did household composition change?
• Is a name, date of birth, Social Security number, alien number, or document number wrong?
• Did the client report employer coverage incorrectly?
• Does the qualifying-event date match the document?
• Is the issue attached to the correct person?

There are two different problems:

Problem 1: The application is accurate, but the trusted data is outdated or incomplete. The client may need to document the accurate current facts.

Problem 2: The application is inaccurate or no longer current. The application may need to be updated before or in addition to submitting documents.

Do not create documentation around information the client has already told you is wrong.

Step 4: Select evidence that addresses the exact mismatch

The document should do more than show that the client exists.

It should address the specific fact the Marketplace is trying to confirm.

For example:

• An income document should show who earned the income, the amount, the period covered, and enough information to support the annual projection.
• A loss-of-coverage document should show the affected person, the type of coverage, and the actual coverage termination date.
• A move document should show the relevant address and date.
• An immigration document should show the applicable document type and identifying information.
• A citizenship document should be complete and legible and satisfy the Marketplace’s document list.
• An employer-coverage document should answer the question the Marketplace asked about availability, affordability, enrollment, or termination.

Step 5: Upload under the correct application and issue

HealthCare.gov’s current upload instructions tell consumers to:

1. log into the Marketplace account;
2. select the application matching the application ID in the notice;
3. select Application details;
4. locate the applicable item under Send documents for data matching issues;
5. select Upload documents or Upload more documents;
6. choose the applicable document type;
7. select and upload the file; and
8. repeat the process for each separate issue.

A checkmark indicates that the file upload succeeded. It does not mean the Marketplace accepted the evidence or resolved the inconsistency. (HealthCare.gov document-upload instructions)

Step 6: Preserve the proof

Keep a record of:

• the eligibility notice;
• client consent applicable to the assistance;
• application review confirmation if information was updated;
• the document submitted;
• file name;
• document category selected;
• date and approximate time of upload;
• affected household member;
• application ID;
• screenshot or other upload confirmation;
• client communication;
• Marketplace follow-up notices;
• Call Center confirmation, if applicable; and
• final eligibility determination.

Agents should apply their agency’s privacy, security, retention, and minimum-necessary-information policies. Do not leave passports, immigration documents, tax records, pay stubs, Social Security information, and Marketplace notices scattered across personal email, unprotected text threads, and local device folders.

Step 7: Track the issue until it closes

“Uploaded” is a workflow stage, not a resolution.

HealthCare.gov says the Marketplace will match submitted documents to the application, review whether the documents confirm the requested information, and contact the consumer if more information is needed.

If the client has not heard anything after approximately one month, HealthCare.gov recommends contacting the Marketplace Call Center to confirm whether the documents were received. If the Call Center confirms receipt, HealthCare.gov says not to submit the same documents again unless the Marketplace asks for more information. If the documents were not received, they should be resubmitted promptly. (What happens after submitting Marketplace documents)

The agent should not close the task until one of these outcomes is documented:

• issue resolved;
• more evidence requested;
• application corrected and reprocessed;
• eligibility changed;
• savings changed;
• coverage eligibility ended;
• case escalated;
• appeal filed; or
• client declined further assistance after being informed of the risk and deadline.

Marketplace document matrix for agents

This table is a triage aid, not an exhaustive list. Use the document list in the client’s notice and the current HealthCare.gov required-documents page.

Resolving an annual income DMI

Income DMIs are often the most difficult because Marketplace eligibility uses projected annual household income, while many documents show only prior-year income, one pay period, or income earned so far.

The right question is not simply:

The better question is:

HealthCare.gov specifically tells consumers whose income changed to use evidence that reflects the year for which coverage is being requested. If a consumer has a different job from last year, current pay stubs may be more useful than documents from the former job. If income is hard to predict, HealthCare.gov identifies a self-employment ledger or Annual Income Letter of Explanation as possible evidence.

Wage income: use the current employment facts

For a consumer with stable wages, useful evidence may include:

• recent pay stubs;
• year-to-date earnings;
• pay frequency;
• anticipated remaining pay periods;
• known overtime or seasonal changes;
• employer wage confirmation; and
• documents showing when a job began or ended.

A practical projection generally considers:

income already received during the year + income reasonably expected during the rest of the year

Example: new job in the middle of the year

Assume a consumer:

• earned $14,000 at a former job before it ended;
• has earned $6,000 at a new job;
• expects to earn another $12,000 before December 31.

The projected annual amount would not be calculated by multiplying the most recent monthly paycheck by 12. The projection would consider both the income already received and the expected remaining income:

$14,000 + $6,000 + $12,000 = $32,000 projected annual income

This is an income-estimation illustration, not tax advice. The client is responsible for the information reported, and tax-household or modified adjusted gross income questions should be referred to an appropriate tax professional.

Do not automatically annualize one unusual pay period

A single pay stub may include:

• overtime;
• a commission;
• a bonus;
• retroactive pay;
• paid-out leave;
• a seasonal surge; or
• an unusually low number of hours.

Before multiplying one pay period across the year, ask whether it represents normal expected earnings.

Self-employment: report net income, not gross revenue

HealthCare.gov instructs self-employed applicants to report net self-employment income, sometimes described as profit, rather than total business receipts.

It also says a self-employment ledger can be a spreadsheet, accounting-software report, handwritten ledger, or another accurate and detailed record of self-employment income and expenses. There is no single required ledger format. (Reporting self-employment income to the Marketplace)

A useful ledger should generally identify:

• consumer or business name;
• type of work;
• period covered;
• income received;
• business expenses;
• resulting net income or loss;
• year-to-date totals; and
• basis for the expected full-year projection.

Example: self-employed consumer

Assume a consumer reasonably projects:

• $54,000 in business receipts; and
• $19,000 in documented business expenses.

The expected net self-employment income would be approximately:

$54,000 − $19,000 = $35,000

The agent should not decide which expenses are deductible or prepare the consumer’s Schedule C. The agent can help the consumer understand what the Marketplace requested, organize the document workflow, and refer tax questions to a qualified tax professional.

Variable, commission, seasonal, and gig income

For irregular income, create a reasonable explanation of how the projection was developed.

That may include:

• income received so far;
• historical seasonal pattern;
• current contracts;
• contracts expected to end;
• expected hours;
• known commission cycles;
• unemployment periods;
• anticipated return to work;
• expected business expenses; and
• other current-year information.

HealthCare.gov provides an annual income calculator and tells consumers to return to the Marketplace and update the application if income changes after submission.

Common income-DMI mistakes

1. Uploading only last year’s return after the client changed jobs. The document may be authentic but may not support the current-year projection.

2. Using gross business revenue as self-employment income. HealthCare.gov asks for net self-employment income.

3. Uploading a pay stub without the client’s name, employer, pay date, or pay period.

4. Ignoring year-to-date income. A projection should not pretend income already earned did not happen.

5. Projecting the remainder of the year without considering a known job termination or contract end date.

6. Changing income merely to produce a desired subsidy result. The application should reflect the consumer’s reasonable, good-faith projection.

7. Assuming an explanation letter must be accepted. A Letter of Explanation may be useful when ordinary documents are unavailable, but the Marketplace decides whether the evidence is sufficient.

8. Giving tax advice outside the agent’s role. Agents should recognize the workflow boundary and refer tax interpretation appropriately.

Resolving a citizenship DMI

A citizenship DMI does not necessarily mean the consumer is not a citizen.

It may result from:

• a name mismatch;
• a recent name change;
• a transposed Social Security number;
• a Social Security Administration record that has not been updated;
• naturalization information that has not matched correctly;
• an incomplete document upload;
• a document attached to the wrong household member; or
• an application-entry error.

The agent should first compare:

• the Marketplace application name;
• date of birth;
• Social Security number;
• citizenship response;
• current legal name; and
• information shown on the supporting document.

Depending on the situation and the Marketplace’s instructions, common evidence may include:

• U.S. passport;
• certificate of citizenship;
• certificate of naturalization;
• state or territorial birth record;
• Consular Report of Birth Abroad;
• certain tribal documentation; or
• a combination of citizenship and identity evidence.

Use the current document list in the eligibility notice rather than relying on a remembered list from a prior year.

Citizenship-document checklist

Before upload, confirm:

• all four corners or the complete document are visible;
• the image is readable;
• the document belongs to the affected household member;
• the name can be connected to the application;
• both sides are included when the reverse contains relevant information;
• no required number or seal is cut off;
• the document is uploaded under the citizenship issue, not income or SEP verification; and
• a name-change document is included if the names materially differ and the Marketplace requests it.

Do not mail original citizenship documents. HealthCare.gov instructs consumers who use mail to send copies, not originals.

Resolving an immigration-status DMI

Immigration-status cases require precision and restraint.

The agent’s role is to help the consumer understand the Marketplace request and follow the document-submission process. The agent should not make legal conclusions about immigration status or advise the client how an immigration filing will affect another legal proceeding.

HealthCare.gov’s current immigration-document list includes documents and identifiers such as:

• Permanent Resident Card, Form I-551;
• Reentry Permit, Form I-327;
• Refugee Travel Document, Form I-571;
• Employment Authorization Document, Form I-766;
• immigrant visa containing temporary I-551 language;
• temporary I-551 stamp;
• Arrival/Departure Record, Form I-94 or I-94A;
• foreign passport;
• Certificate of Eligibility for Nonimmigrant Student Status, Form I-20;
• Certificate of Eligibility for Exchange Visitor Status, Form DS-2019;
• Notice of Action, Form I-797;
• USCIS Acknowledgment of Receipt, Form I-797C;
• certain Office of Refugee Resettlement documents;
• alien registration number or USCIS number; and
• other status-specific records. (HealthCare.gov immigration documentation types)

Immigration DMI checklist

Verify:

• correct affected person;
• full legal name;
• date of birth;
• document type;
• document number;
• alien or USCIS number where applicable;
• I-94 number where applicable;
• country information;
• issuance and expiration information where applicable;
• front and back of the document;
• whether an application response was entered incorrectly; and
• whether the consumer has received a newer document since the application was submitted.

People who are not applying for Marketplace coverage generally do not need to provide their citizenship or immigration status merely because another household member is applying. HealthCare.gov also states that lawfully present immigrants may apply and that immigration information is used to determine Marketplace eligibility and administer insurance-affordability programs.

Privacy warning for agents

Immigration documents contain highly sensitive information.

Do not ask a consumer to send a passport, green card, employment authorization document, or other immigration record through an unprotected group text, shared office inbox, or public upload link.

Use an authorized, access-controlled workflow and keep only the information reasonably needed for the assistance and recordkeeping obligation.

Other Marketplace data matching issues

A DMI is not limited to income, citizenship, and immigration status.

The Marketplace may also request information concerning:

• Social Security number;
• access to employer-sponsored coverage;
• affordability of employer coverage;
• Medicaid or CHIP enrollment or eligibility;
• Medicare or other government coverage;
• American Indian or Alaska Native status;
• incarceration status;
• household relationships; or
• other application information.

The same workflow applies:

1. identify the exact item being verified;
2. determine whether the application is accurate;
3. correct inaccurate information;
4. submit evidence addressing the actual question;
5. preserve proof; and
6. track the result.

Employer coverage

Do not assume every employer letter answers the Marketplace’s question.

The issue may concern:

• whether coverage was offered;
• who was eligible;
• the employee-only premium;
• the family premium;
• the effective date;
• whether the offer met applicable standards;
• whether coverage ended; or
• whether the consumer was enrolled.

Read the notice before asking the employer for a generic “proof of insurance” letter.

Medicaid and CHIP

For a Medicaid or CHIP issue, distinguish among:

• application pending;
• eligibility approved;
• coverage active;
• eligibility denied;
• coverage terminating;
• termination appealed; and
• one household member eligible while another is not.

A family may have children eligible for CHIP while the adults qualify for Marketplace coverage. Keep the household members and effective dates separate.

SEP verification is a separate document workflow

A Special Enrollment Period verification issue concerns the event that permits enrollment outside Open Enrollment. It is not the same as an income or citizenship DMI.

HealthCare.gov currently tells consumers they may have 30 days to submit requested SEP evidence, including evidence concerning events such as marriage, a move, or loss of coverage. The actual notice controls.

Start with an event timeline

Record:

1. What happened?
2. Who was affected?
3. On what date did it happen?
4. When did the consumer receive notice?
5. What was the final day of prior coverage?
6. Did the consumer have prior coverage when the SEP requires it?
7. What proof exists?
8. When was the plan selected?
9. What document deadline appears in the Marketplace account?
10. Has the Marketplace confirmed the SEP?
11. Has the carrier received the enrollment?
12. Has the first premium been paid?

For a comprehensive review of qualifying events and common traps, use the companion ACA Special Enrollment Period Field Guide for Agents.

Loss of coverage

The document should generally establish:

• who lost coverage;
• what coverage was lost; and
• the actual last day covered.

The employee’s last day at work may not be the last day of coverage.

Useful documents can include:

• employer benefits letter;
• carrier termination notice;
• COBRA notice;
• Medicaid or CHIP termination notice;
• government-program notice; or
• another record specified by the Marketplace.

Permanent move

HealthCare.gov says a consumer asked to verify a permanent move may need evidence of:

• the change in residence; and
• prior qualifying coverage when applicable.

Examples can include government correspondence, utility records, rental or mortgage documents, or homeowner’s insurance showing the new address and relevant date. (HealthCare.gov move-SEP documentation)

Marriage

The file may require:

• evidence of the marriage date; and
• evidence that at least one spouse had prior qualifying coverage when that requirement applies.

A marriage certificate may establish the marriage. It does not necessarily establish the prior-coverage element.

Never promise a SEP result from the document alone

The agent can say:

How to upload Marketplace documents correctly

HealthCare.gov says online upload is the fastest and easiest submission method. It does not accept supporting documents by email or fax for the ordinary DMI process.

Current file requirements include:

• PDF, JPEG/JPG, GIF, XML, PNG, TIFF, or BMP;
• maximum file size of 10 MB; and
• file names without prohibited special characters.

The consumer should select the application that matches the ID in the notice and upload the document beside the specific issue under Application details.

Pre-upload quality check

Before selecting Upload, confirm:

• the image is readable at ordinary zoom;
• no page is missing;
• the document is right-side up;
• the client’s name is visible;
• dates are visible;
• amounts and pay periods are visible where relevant;
• the applicable household member is identified;
• both sides are included when necessary;
• the file is under 10 MB;
• the file name has no prohibited characters;
• the correct application year is open; and
• the document is being uploaded under the correct inconsistency.

Use meaningful internal file names

For the agency’s own secure copy, a useful naming convention might be:

ClientLastName_DocumentType_Period_ReceivedDate

For example:

Garcia_PayStubs_July-August_2026-08-18.pdf

Do not place a Social Security number, full alien number, or other unnecessary sensitive identifier in the file name.

A successful upload is not an approval

The checkmark means the Marketplace received the electronic file through the upload interface.

It does not mean:

• the document was legible;
• it was attached to the right person;
• it addressed the requested issue;
• it supported the application amount;
• the Marketplace accepted it; or
• the DMI was resolved.

What happens after documents are submitted?

HealthCare.gov describes three steps:

1. match the documents with the application;
2. review whether each document confirms the needed information; and
3. contact the consumer if more information is required.

The client may later receive:

• a notice that the documents are under review;
• a notice requesting additional evidence;
• an updated eligibility determination;
• a change in premium tax credit or cost-sharing reduction;
• a coverage-eligibility change; or
• continued reminder messages while documents remain under review.

If the Marketplace Call Center confirms that documents were received, HealthCare.gov says not to keep resubmitting the same evidence merely because automated reminders continue. Duplicate submissions can make the file harder to follow.

Suggested agent status stages

Use separate statuses:

• Notice received
• Client contacted
• Facts under review
• Application correction required
• Documents requested
• Documents received
• Documents reviewed by agent
• Uploaded
• Receipt confirmed
• Marketplace review pending
• Additional evidence requested
• Resolved
• Eligibility changed
• Escalated
• Appeal pending
• Client declined assistance

Do not use one status called “DMI handled.” It hides where the case actually stands.

Calling the Marketplace about a DMI

The Health Insurance Marketplace Call Center number is 1-800-318-2596, with TTY service at 1-855-889-4325. HealthCare.gov currently states that the Call Center is available 24 hours a day, seven days a week, except holidays. (HealthCare.gov contact information)

Before calling, have:

• consumer available or properly represented;
• documented authorization appropriate to the assistance;
• application ID;
• eligibility-notice date;
• affected household member;
• issue type;
• deadline;
• document file name;
• upload date;
• approximate upload time;
• screenshot or upload confirmation;
• current Marketplace messages; and
• specific question you need answered.

Ask precise questions:

• Has the Marketplace received the document?
• Which issue is the document attached to?
• Is the document currently under review?
• Is additional information required?
• Has an updated notice been generated?
• Is the inconsistency still open?
• What deadline is currently shown?
• What is the reference number for this call?

Document:

• date and time;
• Call Center representative’s name or identifier when provided;
• reference number;
• issue discussed;
• answer given;
• next action; and
• next follow-up date.

Do not ask the consumer to share a Marketplace password or security code with the agent. HealthCare.gov’s fraud guidance says Marketplace representatives will not ask for the consumer’s Marketplace account password or security code.

What if the DMI is not resolved?

First determine why.

Possible explanations include:

• the document was never received;
• the wrong application was selected;
• the document was uploaded under the wrong issue;
• a page was missing;
• the file was unreadable;
• the document did not address the requested period;
• the document supported a different income than the application;
• the application should have been updated;
• the Marketplace needs a second form of evidence;
• the document belongs to a different household member;
• the issue remains under review; or
• the Marketplace issued an adverse eligibility determination.

Do not immediately upload the same file again.

Obtain the latest notice or Call Center status and determine the actual next step.

Marketplace appeals

If the Marketplace issues an eligibility decision the consumer believes is incorrect, an appeal may be available.

HealthCare.gov says consumers generally have 90 days from the date of the Eligibility Notice to request an appeal. It also says that when the Marketplace first asks for documents to confirm application information, the consumer should generally submit those documents before appealing because the updated eligibility decision may resolve the issue. (What Marketplace decisions can be appealed)

An appeal is different from an ordinary DMI upload.

Before discussing an appeal, identify:

• the exact decision;
• date of the decision;
• stated appeal deadline;
• whether documents were already submitted;
• whether an updated notice was issued;
• whether coverage or savings changed;
• whether the client has an urgent medical need; and
• whether the client needs legal, tax, immigration, or other professional assistance.

HealthCare.gov advises consumers with coverage to remain enrolled and continue paying premiums during an appeal, because dropping or losing coverage can create additional enrollment problems. It also warns that continued advance premium tax credits during an unsuccessful appeal can create repayment consequences. (How to file a Marketplace appeal)

Agents should explain the operational choices without presenting themselves as attorneys or tax advisers.

Five ACA DMI scenarios agents will see

Scenario 1: the client changed jobs after filing the prior tax return

Client says: “My tax return says $48,000, but I lost that job. I expect to make only $31,000 this year.”

Agent analysis:

• Is $31,000 still the client’s reasonable current-year projection?
• How much was earned before the old job ended?
• How much has been earned at the new job?
• What is expected for the rest of the year?
• Does the application include both jobs correctly?
• Does the notice request current income evidence?

Useful evidence may include:

• termination or final-pay information from the former job;
• current-job pay stubs;
• employer wage statement;
• year-to-date earnings; and
• explanation of the annual projection.

Agent trap: Uploading only the old tax return because it is an official document, even though it does not support the current application.

Scenario 2: a self-employed client reported gross receipts

Client says: “My business brings in about $70,000, so that’s what we put as income. But I spend about $30,000 running it.”

Agent analysis:

• Did the application report gross business receipts instead of net self-employment income?
• Does the application need to be corrected?
• Does the consumer have an accurate ledger?
• Are income and expenses documented for the relevant period?
• Does the full-year projection remain reasonable?

Useful evidence may include:

• detailed ledger;
• accounting report;
• profit-and-loss information;
• current contracts;
• documentation of business expenses; and
• Annual Income Letter of Explanation where appropriate.

Agent trap: Making a tax determination for the client instead of documenting the consumer’s information and referring tax questions.

Scenario 3: a naturalized citizen has a citizenship DMI

Client says: “I became a citizen several years ago. Why does the Marketplace say it cannot verify me?”

Agent analysis:

• Does the Marketplace application use the correct legal name?
• Has the name changed?
• Is the Social Security number correct?
• Does the citizenship document match the affected person?
• Was the full document uploaded?
• Was it attached under the correct issue?

Useful evidence may include:

• U.S. passport;
• certificate of naturalization;
• certificate of citizenship; or
• another document listed by the Marketplace.

Agent trap: Telling the client the notice means the government disputes the client’s citizenship. The notice establishes a mismatch requiring resolution, not the reason for it.

Scenario 4: loss-of-coverage proof shows the employment end date but not the coverage end date

Client says: “My employer letter says I stopped working June 12.”

Agent analysis:

The Marketplace may need the last day of health coverage, which could be June 12, June 30, or another date.

Better evidence may include:

• benefits termination letter;
• carrier notice;
• COBRA election notice; or
• employer statement specifying the last covered day.

Agent trap: Treating “last day worked” and “last day insured” as interchangeable.

Scenario 5: the document was uploaded to the wrong application

Client says: “I uploaded the pay stubs two weeks ago, but the notice is still there.”

Agent analysis:

• Did the client select the application ID shown in the notice?
• Was an old coverage-year application open?
• Was the document uploaded under income or merely stored elsewhere?
• Did the upload display a success checkmark?
• Does the Call Center confirm receipt?
• Is a separate income issue open for another household member?

Agent trap: Submitting the same document repeatedly without locating the original upload.

Client communication scripts

Initial document request

Upload confirmation

Request for better evidence

One-month follow-up

Adverse-decision message

Agency SOP for Marketplace data matching issues

A strong agency procedure should answer five questions:

1. Who owns the case?
2. What is due?
3. What evidence was submitted?
4. What is the current Marketplace status?
5. What proves the agency followed through?

Recommended DMI case fields

• Consumer name
• Household member affected
• Application ID
• Coverage year
• Marketplace
• Issue category
• Notice date
• Exact deadline
• Application information being verified
• Whether application correction is required
• Documents requested
• Secure document-receipt date
• Agent reviewing evidence
• Upload date
• Document category selected
• Upload proof location
• Call Center reference number
• Marketplace status
• Additional-information request
• Next follow-up date
• Final determination
• Resolution date
• Related consent record
• Related application-review confirmation
• Notes and client communications

Suggested internal controls

Intake control: Every eligibility notice is reviewed before being assigned a generic task.

Deadline control: The deadline comes from the notice, not from an assumed 90-day rule.

Evidence control: A second review confirms that the document addresses the requested fact and affected person.

Upload control: The agent records the application ID, issue category, document type, and upload confirmation.

Follow-up control: Uploaded cases remain on an open-work queue until the Marketplace issues a result.

Privacy control: Sensitive documents are transmitted and stored through approved, access-controlled methods.

Escalation control: Cases nearing a deadline, involving loss of coverage or savings, or requiring an appeal receive priority review.

Closure control: The final notice or Call Center resolution is preserved before the case is marked complete.

Common agent mistakes with ACA data matching issues

1. Treating a DMI as an automatic denial

A client may still be permitted to enroll when the eligibility notice says the client can purchase a Marketplace plan, even though documents remain outstanding. HealthCare.gov warns that eligibility or savings may later change if the issue is not resolved.

2. Treating a successful upload as resolution

The upload checkmark is only confirmation that the file was uploaded.

3. Uploading evidence without checking whether the application is wrong

A document cannot make inaccurate application information accurate.

4. Using a prior-year tax return for a materially changed current year

The return may be valid but irrelevant to the current projection.

5. Uploading gross business receipts for self-employment income

HealthCare.gov instructs self-employed applicants to report net income.

6. Uploading documents under the wrong household member

A family application can contain several simultaneous issues.

7. Missing the SEP verification deadline because the agent assumed it was a 90-day DMI

SEP verification generally uses a shorter deadline.

8. Advising the client to invent or manipulate income

Income should reflect the consumer’s reasonable projection—not the number needed to create a preferred premium.

9. Giving tax or immigration advice

Explain the Marketplace workflow and refer specialized interpretation.

10. Emailing sensitive documents insecurely

A passport, tax return, green card, pay stub, Social Security record, or Marketplace notice should not be left in an uncontrolled inbox.

11. Resubmitting duplicates without checking receipt

HealthCare.gov says not to resend the same documents after the Call Center confirms receipt unless additional information is requested.

12. Closing the task before the final determination

The agent should know whether the issue was accepted, rejected, corrected, escalated, or appealed.

ACA Marketplace DMI checklist for agents

Notice review

• Obtain the actual eligibility or verification notice.
• Confirm the Marketplace and coverage year.
• Record the application ID.
• Identify the affected household member.
• Classify the issue as DMI, SEP verification, identity proofing, periodic matching, or another process.
• Record the exact deadline.
• Review the Marketplace’s listed acceptable documents.

Application review

• Confirm current consumer authorization.
• Compare the notice with the application information.
• Ask whether income, employment, address, household, or coverage changed.
• Check names, dates of birth, Social Security numbers, and document numbers for entry errors.
• Correct inaccurate application information.
• Obtain the consumer’s review and confirmation before submitting an application change.

Document preparation

• Select evidence that addresses the exact requested fact.
• Confirm the document belongs to the affected person.
• Confirm dates, amounts, pay periods, coverage dates, or document numbers are visible.
• Include all pages and both sides when needed.
• Confirm the image is legible.
• Confirm the file is under 10 MB.
• Remove prohibited characters from the file name.
• Do not include unnecessary sensitive identifiers in the file name.

Upload

• Select the application matching the notice.
• Open Application details.
• Upload beside the correct issue.
• Choose the correct document category.
• Confirm the successful-upload indicator.
• Repeat separately for every open issue.
• Preserve the submitted file and upload proof.

Follow-up

• Tell the client the upload is pending review.
• Track new Marketplace notices.
• Confirm receipt if there is no update after approximately one month.
• Do not send duplicates when receipt has been confirmed.
• Respond promptly to requests for additional information.
• Preserve the final determination.
• Escalate or review appeal rights when appropriate.
• Do not mark the case resolved until the final status is documented.

Make DMI follow-up a client workflow, not an inbox search

Data matching issues create several different records:

• consumer consent;
• application information;
• application-review confirmation;
• eligibility notice;
• supporting documents;
• upload proof;
• Marketplace messages;
• Call Center notes;
• follow-up tasks; and
• final eligibility determination.

When those records are divided among texts, personal email, a Marketplace portal, an EDE platform, a desktop folder, and a CRM note, the agent may not be able to reconstruct the file when the client calls or when a document is requested later.

Informed + Choice ACA Compliance Vault helps licensed agents document ACA consumer consent and eligibility application review, store Marketplace notices and supporting files, connect records to the client, and keep the file searchable and exportable.

It works beside the agent’s existing Marketplace, EDE, quoting, agency, and enrollment systems.

It does not replace HealthCare.gov, determine Marketplace eligibility, certify that a document will be accepted, provide tax or immigration advice, or eliminate the agent’s responsibility to follow current CMS, Marketplace, carrier, agency, and state requirements.

Bottom line

An ACA Marketplace data matching issue is not resolved merely because the client sent a document to the agent or because an upload displayed a checkmark.

The agent needs a complete workflow:

1. read the actual notice;
2. identify the person, issue, and deadline;
3. verify the underlying application facts;
4. correct inaccurate information;
5. collect evidence that addresses the exact question;
6. upload it under the correct application and issue;
7. preserve proof;
8. track the Marketplace review; and
9. document the final outcome.

The agent who treats a DMI as a one-time upload may lose track of the case.

The agent who treats it as a managed eligibility workflow can help the client avoid preventable loss of coverage, premium tax credits, cost-sharing reductions, or an enrollment opportunity.

Related agent resources

• ACA Special Enrollment Periods: Practical Field Guide for Agents
• ACA Consumer Consent vs. Application Review
• ACA Compliance and Marketplace Operations for Agents
• ACA Consumer Consent and Eligibility Review Tools
• Marketplace Quoting for ACA Agents

Sources

• Data matching issue definition: HealthCare.gov Accessed 2026-08-18.
• When the Marketplace needs more information: HealthCare.gov Accessed 2026-08-18.
• Required documents and deadlines: HealthCare.gov Accessed 2026-08-18.
• How to upload documents: HealthCare.gov Accessed 2026-08-18.
• What happens after documents are submitted: HealthCare.gov Accessed 2026-08-18.
• Reporting self-employment income: HealthCare.gov Accessed 2026-08-18.
• How Marketplace application data is used: HealthCare.gov Accessed 2026-08-18.
• Immigration documentation types: HealthCare.gov Accessed 2026-08-18.
• Marketplace appeals: HealthCare.gov Accessed 2026-08-18.
• Annual Income DMI Checklist for Agents and Brokers: Centers for Medicare & Medicaid Services Accessed 2026-08-18.
• SEP Verification Issue Checklist for Agents and Brokers: Centers for Medicare & Medicaid Services Accessed 2026-08-18.
• Agent and Broker Video Learning Center: Centers for Medicare & Medicaid Services Accessed 2026-08-18.
• 2027 Payment Notice final-rule fact sheet: Centers for Medicare & Medicaid Services Accessed 2026-08-18.
• City of Columbus v. Kennedy July 16, 2026 order: U.S. District Court for the District of Maryland Accessed 2026-08-18.

Frequently Asked Questions

What is an ACA Marketplace data matching issue?

A data matching issue is a difference between information on a Marketplace application and information available through another trusted data source. It may concern income, citizenship, immigration status, other health coverage, Social Security information, or another eligibility fact.

Does a DMI mean the client did something wrong?

Not necessarily. A mismatch may result from changed income, a new job, outdated agency data, a name change, a recent immigration or citizenship update, an application-entry error, or another legitimate difference.

Can a client enroll while a DMI is open?

When the eligibility notice says the consumer can purchase a Marketplace plan, the consumer can generally enroll even though documents are still required. Coverage eligibility or financial assistance may later change if the issue is not resolved by the deadline.

How long does a consumer have to resolve a Marketplace DMI?

HealthCare.gov generally lists 90 days for issues such as household income, 95 days for citizenship or immigration status, and 30 days for SEP verification. The date in the actual Marketplace notice controls.

Is SEP verification the same as a data matching issue?

No. A DMI concerns a mismatch between application information and another data source. SEP verification concerns proof of the qualifying event that permits enrollment outside Open Enrollment.

What documents can resolve an income DMI?

Depending on the facts, useful evidence may include recent pay stubs, a current employer statement, W-2, a still-representative tax return, unemployment statement, benefit letter, self-employment ledger, profit-and-loss information, or an Annual Income Letter of Explanation.

Should an agent use the client's last tax return to calculate current Marketplace income?

Not automatically. Marketplace eligibility uses projected annual household income for the coverage year. Current pay stubs or other evidence may be more relevant after a job, wage, contract, or self-employment change.

Does self-employed income mean gross revenue?

No. HealthCare.gov instructs self-employed applicants to report net self-employment income, sometimes described as profit, after applicable business expenses.

Can an agent email documents to HealthCare.gov?

No. HealthCare.gov says ordinary DMI documents cannot be submitted by email or fax. Consumers can generally upload documents through the Marketplace account or mail copies using the instructions and address provided.

What file types can be uploaded?

HealthCare.gov currently accepts PDF, JPEG or JPG, GIF, XML, PNG, TIFF, and BMP files, generally up to 10 MB. File names cannot contain certain special characters.

How does an agent know whether a document was accepted?

A successful-upload indicator only confirms upload. The Marketplace later reviews the document and issues a notice or requests more information.

Should documents be uploaded again when reminder emails continue?

Not automatically. If the Marketplace Call Center confirms that the documents were received, HealthCare.gov says not to resubmit the same documents unless more information is requested.

What if the consumer missed the document deadline?

HealthCare.gov advises consumers to submit documents even after a missed deadline because they may be able to requalify for savings or coverage. Review the current eligibility determination, effective date, and appeal instructions.

Can an agent guarantee that a listed document will resolve the issue?

No. An agent can identify documents the Marketplace lists and help with the workflow, but the Marketplace determines whether the evidence verifies eligibility.

How long should an agent keep DMI records?

Follow applicable federal and state requirements, Marketplace guidance, carrier and agency policies, privacy rules, and professional advice. Keep supporting notices, documents, upload evidence, and resolution records connected to the applicable client and application file.