In this Beyond the Basics webinar presented by the Center on Budget and Policy Priorities on September 28, 2021, Tara Straw, Director of Health Insurance and Marketplace Policy, and Shelby Gonzales, Vice President for Immigration Policy, provide guidance on how to help consumers complete the Marketplace documentation requirements. They explain both how to prevent data matching issues from occurring and how to resolve them when they do occur.

↓ View Presentation Slides (PDF)

Jump to:

Overview of Data Matching Issues

• Use of electronic data matching & limitations
• What happens when there is a data matching issue
• Data matching issue notices

Verification of Citizenship & Immigration Status

• Citizenship verification process on the marketplace
• Reasons citizenship data matching may be unsuccessful
• Documents that can be used to verify citizenship
• Immigration status verification process on the marketplace
• Reasons immigration status data matching may be unsuccessful
• Documents that can be used to verify immigration status
• Examples

Verification of Household Income

• Reasons data matching may be unable to verify income
• General rules for income verification
• Documents that can be used to verify income
• Guide to resolving income data matching issues
• Examples

Verification of Other Minimum Essential Coverage

• Overview of minimum essential coverage data matching issues
• Periodic data matching notices

General Tips to Prevent & Resolve DMIs

• Tips to prevent data matching issues
• Tips to resolve data matching issues

Identity Proofing for HealthCare.gov

• Process for identity proofing
• Documents used for identity proofing
• Troubleshooting failed identity proofing

Additional Resources

Reference Guide to Immigration Documents

Yearly Income Guidelines and Thresholds

Troubleshooting Failed Identity Verification

In this Health Reform: Beyond the Basics webinar presented on September 29, 2020, Tara Straw, Senior Policy Analyst, and Shelby Gonzales, Director of Immigration Policy, provide guidance on how to help consumers complete the Marketplace documentation requirements; they cover both how to prevent data matching issues from occurring and how to resolve them when they do occur.

↓ View Presentation Slides (PDF)

Jump to:

Overview of Data Matching Issues

• Limitations of electronic data matching
• What happens when there’s a data matching issue
• Data-matching issue notices

Verification of Citizenship and Immigration Status

• How the marketplace verifies citizenship and immigration status
• Reasons data matching may be unsuccessful
• Document types that can be used to prove citizenship and status
• Examples

Verification of Household Income

• General rules for verification of income
• Reasons data matching may not verify income
• Documents that can be used to verify income
• Examples

Verification of Other Minimum Essential Coverage

• Minimum essential coverage DMIs
• Periodic data matching

Identity Proofing for HealthCare.gov

• Process for ID proofing
• Document types to prove identity
• Process for people unable to complete identity proofing

General Tips to Prevent and Resolve DMIs

• Tips to prevent DMIs
• Tips to resolve DMIs

Additional Resources

Reference Guide to Immigration Documents

Yearly Income Guidelines and Thresholds

In this Health Reform: Beyond the Basics webinar presented on October 10, 2019, Tara Straw, Senior Policy Analyst, and Shelby Gonzales, Director of Immigration Policy, provide information about how to help consumers complete documentation requirements related to enrollment in health coverage programs. They cover how to prevent “data-matching” issues from occurring when possible and how to resolve them when they do occur.

↓ View Presentation Slides (PDF)

Watch the Webinar

Additional Resources

Reference Guide: Documents Used to Verify Immigration Status

Reference Guide: Yearly Guidelines and Thresholds

Beyond the Basics Webinar Series | View all webinars

Key Facts About Health Reform | View all key facts

Tools and Resources | View all tools and resources

Frequently Asked Questions | View FAQs

In this special Health Reform: Beyond the Basics webinar presented in partnership with the National Immigration Law Center (NILC) on September 23, 2018, Shelby Gonzales, Senior Policy Analyst at the Center on Budget and Policy Priorities, and Sonya Schwartz, Senior Policy Attorney at NILC,  provide an overview of eligibility for the premium tax credit and Medicaid based on immigration status, touch on understanding and addressing concerns immigrants may have when applying for health programs, and provide tips on how to navigate the application process for families that include immigrants.

Presentation Slides

↓ View presentation slides (PDF)

Watch the Webinar

Overview of What’s Covered

Eligibility for Medicaid and CHIP Based on Immigration Status

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• Eligible immigration statuses for Medicaid and the Children’s Health Insurance Program (CHIP)
• 5-year waiting period
• State flexibility

Eligibility for Marketplace Coverage Based on Immigration Status

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• Eligible immigration statuses for Marketplace coverage
• Example: Eligibility based on immigration status

Special Marketplace and PTC Eligibility

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• Special Marketplace rules for seniors
• PTC for certain lawfully present people with low income
• Special rule for married nonresidents

Understanding & Addressing Concerns Immigrants May Have When Applying for Health Programs

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• Concerns related to use of public benefits and proposed “public charge” rule
• Addressing concerns related to privacy
• Nonapplicants’ protections related to immigration status
• Requests for Social Security Numbers (applicants vs. nonapplicants)
• Tips for talking about immigration status

Navigating the Application Process

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• Eligibility verification for citizenship and immigration status | Webinar: Preventing & Resolving Data-Matching Issues
• Documents to prove immigration status
• Documents to prove citizenship
• Processes for resolving DMIs for certain lawfully present people with low income | Explainer: Subsidy Eligibility for Immigrants Ineligible for Medicaid Due to Status

Q&A

Additional Resources

Resources | View resources links

National Immigration Law Center | Find out more

• Tips for Addressing Immigrant Families’ Concerns When Applying for Health Coverage Programs

Reference Guide: Document Used to Verify Immigration Status | Reference Guide

Webinar OE6: Preventing and Resolving DMIs | Webinar

Explainer: Subsidy Eligibility for Immigrants Ineligible for Medicaid Due to Status | Explainer Video

Key Facts:

• Immigrant Eligibility for Health Coverage Programs
• Helping Families that Include Immigrants Apply for Health Coverage

Beyond the Basics Webinar Series | View all webinars

Key Facts About Health Reform | View all key facts

Tools and Resources | View all tools and resources

Frequently Asked Questions | View FAQs

In this Health Reform: Beyond the Basics webinar presented on October 11, 2018, Shelby Gonzales, Senior Policy Analyst, and Tara Straw, Senior Policy Analyst, detail how assisters can help people prevent and resolve data-matching issues that arise when the marketplace determines that information people provide as to their income or citizenship or immigration status doesn’t match information available through the federal data hub.

Presentation Slides

↓ View presentation slides (PDF) 

Watch the Webinar

Overview of What’s Covered

Data-Matching Process

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Data-matching process to verify eligibility factors

• General process when there is a data-matching issue
• Notices for a data-matching issue

Verification of Citizenship and Immigration Status

Jump to video section, View slides  

Process for verification of citizenship

• Reasons data matching may be unsuccessful
• Documents that can be used to prove U.S. citizenship

Process for verification of immigration status

• Reasons data matching may be unsuccessful
• Documents and needed document numbers to prove immigration status
• Reference Guide: Documents Used to Verify Immigration Status

Example: Immigration and citizenship verification

Verification of Household Income

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Process for verification of income

• New DMI for some with income near the poverty line

• Reasons data matching may not verify income
• Example documents that can be used to verify income
• Marketplace guide for income data-matching issues

Examples:

• Expected income goes down
• No previous tax data
• Early retirement

Failure to resolve income data-matching issue

Verification of Other Minimum Essential Coverage

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Resolving data-matching issues regarding other minimum essential coverage

Identity Proofing

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Healthcare.gov process for identity proofing

• Documents that can be used to prove identity
• If identity can’t be verified

General Tips to Prevent and Resolve DMIs

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Tips:

• To prevent data-matching issues
• To resolve data-matching issues
• On sending documentation to resolve data-matching issues
• To prevent data-matching issues

Q&A

Additional Resources

Resources | View resources links

Reference Guide: Documents Used to Verify Immigration Status

Reference Guide: Yearly Guidelines and Thresholds

Webinar OE6: Determining Households and Income

Beyond the Basics Webinar Series | View all webinars

Key Facts About Health Reform | View all key facts

Tools and Resources | View all tools and resources

Frequently Asked Questions | View FAQs

↓ Read the final rule

↓ Read the guidance on hardship exemptions 

For an overview of the rule changes, see our paper, “Health Care Rule Changes Will Harm Consumers,” detailing how these changes will weaken benefit standards, likely harming people with pre-existing conditions; raising new barriers for people who want to enroll in health coverage; and reducing accountability for insurers and transparency for consumers.

Changes from the final rule and additional guidance include:

Altered rules for navigator programs.  Under the rule, marketplaces are permitted to have just one navigator entity serve the entire state. In addition, the rule allows navigators to not have a physical presence in the state they are paid to serve and no longer requires that one navigator group in a service area be a consumer-focused nonprofit organization.

New requirements for verification of income.  The rule requires individuals to verify their income if their attested income is above the poverty line but data sources suggest that income is below the poverty line. This will make it harder for eligible individuals with fluctuating poverty-level income to access much-needed financial help to afford coverage.

Expanded hardship exemption.  Effective immediately, new guidance expands the situations in which people can receive a hardship exemption to include people who:

• Show that a lack of choice when there is only one issuer in their area “precluded” them from obtaining coverage;
• Cannot buy an affordable plan that does not include abortion coverage, which is contrary to the individual’s beliefs;
• Have no qualified health plan in their area (a circumstance no marketplaces have ever experienced); or
• Experience personal circumstances that may qualify as a hardship, such as when available QHPs don’t cover needed specialty care.

New special enrollment period (SEP) for loss of pregnancy-related coverage provided through CHIP.  The rule adds an additional SEP for the loss of coverage provided through the Children’s Health Insurance Program (CHIP) “unborn child” option, which only covers pregnancy-related services and is not considered minimum essential coverage. This SEP will go into effect on June 18, 2018.

Removes requirement to provide adequate notice to those who fail to reconcile APTC.  People who receive APTC are required to file a tax return and reconcile the tax credit, or they risk losing financial assistance when they re-enroll. Current rules require that the Marketplace must first provide enrollees with information about failure to reconcile, giving them a chance to correct the record if they in fact reconciled or remedy the situation by filing a tax return, but the new rule removes that requirement to first send notice directly to the tax filer before discontinuing APTC.

Allows states and insurers to scale back benefits.  Beginning in 2020, the new rule changes the standards for how states create a benchmark plan to establish the minimum standard for the ten essential health benefits offered in that state and how insurers comply with them, opening up new ways for states and insurers to scale back coverage of services that are costly but critical to people with serious health needs.

There are additional changes in the rule including weakening the risk adjustment program by letting states shrink risk adjustment transfers by up to 50%, reduced transparency of insurance premium rates, and diminished standards for the “medical-loss ratio” requiring insurers to spend at least 80% of what they collect in premiums on medical care and improving healthcare quality. For more detailed information on the harmful changes in this rule, please see our paper, “Health Care Rule Changes Will Harm Consumers.”

Verifying Immigration Status in Healthcare.gov

November 2017

Many non-citizens in the United States are eligible for health coverage through Medicaid, the Children’s Health Insurance Program (CHIP), or subsidized plans in the Affordable Care Act (ACA) Marketplaces. In Healthcare.gov, non-citizens applying for coverage for themselves are asked to select from a drop down list of immigration document types and to provide specific numbers from their documents to prove their immigration status. This information is used by Healthcare.gov to verify applicants meet the immigration status requirement for enrollment. Those not applying for coverage are not asked to provide information about their status.

This reference guide walks through examples of the different immigration document types that can be used in Healthcare. gov and notes where different document numbers are located.

↓ View reference guide (PDF)

Note: This list is not a comprehensive list of all documents eligible immigrants may have and does not address what should be done if someone does not have one of the documents on the Healthcare.gov list. For more information on statuses that are considered an “eligible immigration status” for ACA Marketplaces, Medicaid and CHIP, see our Webinar: Immigrant Eligibility for Health Coverage Programs.

Families that include immigrants may experience barriers when applying for health coverage.  The following questions and answers explains issues that families may face and provides information about key concerns families with immigrants may have when completing the application process.  (For more information on immigrant eligibility, please see Key Facts You Need to Know About: Immigrant Eligibility for Health Insurance Affordability Programs.)

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PART I: Eligibility policies affecting immigrants in Medicaid, the Children’s Health Insurance Program (CHIP), and the federal and state marketplaces.

Will enrolling in insurance affordability programs have an impact on immigrants when they apply to change their immigration status?

No. When individuals apply for legal permanent resident status, immigration authorities determine whether someone is likely to become dependent on the government for subsistence, commonly referred to as a “public charge.”  This evaluation does not take into account whether someone applied for or received Medicaid, CHIP, or subsidized coverage in the marketplaces.  Thus, applying for or receiving these benefits does not have a negative impact on immigrants when they apply to change their status.  There is an exception:  people receiving long-term institutional care through Medicaid may be considered dependent on the government.

Can people apply for health coverage for other household members even if they are not applying for coverage for themselves (or are ineligible)?

Yes, households of people applying for insurance affordability programs can include both applicants and non-applicants.  During the application process, the person completing the application will state who is in the household and which household members are applying for coverage.  Non-applicants must include information such as their income and plans for tax filing, but they are not required to provide information about their immigration or citizenship status.

Is having a Social Security number (SSN) an eligibility requirement for insurance affordability programs?

For Medicaid and CHIP, individuals seeking coverage for themselves are generally required to provide their SSNs if they are eligible for one (unless they have a religious objection to getting an SSN).  If they are eligible for but do not have an SSN, they must apply for one and the Medicaid or CHIP agency must offer to help them apply.  They cannot be denied coverage while their application for an SSN is being processed.

Individuals seeking to enroll in a marketplace plan for themselves must provide an SSN if they have one.

Is an SSN required if an individual is applying for premium tax credits for a family member and not himself?

Individuals applying for premium tax credits for their dependents or spouse and not for themselves only need to provide their SSN if: (1) they have an SSN, and (2) they filed a tax return for the year for which tax data would be used to verify their household income and family size.  (Eligibility for the 2016 coverage year uses information from the 2014 tax return year to verify that information.)  Providing SSNs of non-applicants who have them is strongly encouraged.  The marketplaces use SSNs to conduct data matches with trusted data sources like the Social Security Administration (SSA) and the Internal Revenue Service (IRS).  When these matches can successfully verify key information like income, consumers may not have to submit proof of their circumstances.

Will a parent applying for Medicaid or CHIP coverage for his child but not for himself be required to provide an SSN?

Parents who apply for Medicaid or CHIP for their children do not have to provide an SSN.  If they have one and choose to provide it, this may help the Medicaid agency electronically verify income for the family, but it is not required.

Can a person who has an Individual Taxpayer Identification Number (ITIN) to file taxes use that number instead of an SSN on the application?

No.  ITINs are not the same as SSNs.  The application will verify SSNs with the Social Security Administration, which cannot verify ITINs.   Someone who uses an ITIN to file taxes is not required to provide an SSN on the application and should skip the question in the application.  (The application will make multiple requests for the SSN; each time the consumer should skip it.)

Can someone include a tax dependent that lives abroad in his application? 

Applicants must include information on all members of the household, including any tax dependents living abroad, for the purpose of determining the applicant’s household size and income.  Dependents living abroad will generally not be eligible to enroll in health insurance coverage.  The Healthcare.gov application asks for the address of all tax dependents but does not accept foreign addresses.  Consumers can put in the address of the tax filer in place of the address for tax dependents who live abroad.

Can information provided in the application be used for immigration civil enforcement purposes? 

No.  Medicaid, CHIP, and the marketplaces use the U.S. Citizenship and Immigration Services’ (USCIS) Systematic Alien Verification for Entitlements (SAVE) program to verify the citizenship or immigration status of people applying for coverage.  However, this data match is only for the purpose of confirming that applicants meet the immigration or citizenship status requirement to enroll in an insurance affordability program.  The USCIS has issued guidance that information about applicants or households obtained for health insurance eligibility will not be used for civil immigration enforcement purposes.

PART II: Applying for premium tax credits in the Federally-Facilitated Marketplace

Who needs to complete remote identity proofing (i.e. ID proofing) to submit an application on Healthcare.gov?

The Federally-Facilitated Marketplace (FFM) uses Healthcare.gov to process applications for and enroll eligible applicants in health coverage.  Healthcare.gov requires the person designated as the household contact in an application (who must be an adult) to successfully complete ID proofing to ensure that he is who he says he is before he can use the online process to apply for coverage, select health insurance plans, report changes, or renew coverage.

Why are some people not able to complete the ID proofing process on Healthcare.gov? 

Experian, the entity that verifies identity for Healthcare.gov, creates personalized questions that the household contact must answer to prove his identity in the application.  Experian often cannot generate a sufficient number of questions for household contacts with limited or no credit history.  Also, consumers have sometimes found questions generated by Experian difficult to answer.

What happens when ID proofing cannot be completed on Healthcare.gov?

When Healthcare.gov cannot complete ID proofing online, it gives household contacts a unique reference code and instructs them to call the Experian Help Desk to complete ID proofing over the phone.

What happens when ID proofing cannot be completed over the phone with Experian?

Household contacts who cannot complete ID proofing over the phone have to submit supporting documents to prove their identity if they wish to submit an application online.  They can upload electronic versions of the documents to their Healthcare.gov accounts, or can mail copies to:

Health Insurance Marketplace
465 Industrial Boulevard
London, KY 40750-0001

Table 1 lists the documents that can be used to verify identity.  When mailing copies, it is important to include the unique reference ID number provided during the online ID proofing process so the documents can be matched to the correct account.

What if consumers do not have any of the documents listed to complete Healthcare.gov’s ID proofing process?

Household contacts who do not have any of the documents needed to complete the ID proofing process will not be able to submit an application online on Healthcare.gov.  Instead, they may complete the application by mailing a completed paper application form or may apply over the phone by contacting the marketplace call center at 1-800-318-2596 (TTY: 1-855-889-4325).  They should ask to receive notices about their application by mail.  If they qualify for marketplace coverage, they will need to go through the marketplace call center to select and enroll in a plan.  To evaluate their health plan options before enrolling, applicants can use the “See plans” tool on Healthcare.gov.  Once enrolled, they will need to report any changes and complete the renewal process through the marketplace call center.

How does Healthcare.gov verify citizenship? 

In the FFM, when applicants attest to being U.S. citizens and provide an SSN, their information is checked against information in SSA’s records to verify citizenship.

SSA does not have citizenship records for some citizens, including many who were born outside the U.S.  If citizenship cannot be verified electronically through SSA, applicants are asked if they are a naturalized or derived citizen.  Some applicants who are naturalized or derived citizens can have their status verified instantly by providing numbers found in their Certificate of Citizenship or Certificate of Naturalization that will be matched with information in the SAVE program.

The SAVE program cannot immediately verify citizenship status of all derived and naturalized citizens.  When this occurs, applicants will have to upload proof of their citizenship to their Healthcare.gov accounts (see list of acceptable proof in Table 2).  Applicants can also mail document copies to:

Health Insurance Marketplace
465 Industrial Boulevard
London, KY 40750-0001

While their citizenship is being verified, applicants who otherwise meet all eligibility requirements can enroll in Medicaid, CHIP, or a marketplace plan during a “reasonable opportunity period” or “inconsistency period.”

How does Healthcare.gov verify immigration status? 

In the FFM, all non-citizens applying for coverage for themselves must attest to having an “eligible immigration status.”  They then must select a document type to use to prove their immigration status.  They will be asked to provide one or two numbers from their document; Healthcare.gov will use this information to attempt to immediately verify their immigration status through the SAVE program.

The SAVE program cannot immediately verify the status of all immigrants.  When this occurs, applicants will have to upload proof of their immigration status to their Healthcare.gov accounts (see list of acceptable proof in Table 3).  Applicants can also mail document copies to:

Health Insurance Marketplace
465 Industrial Boulevard
London, KY 40750-0001

While the applicant gathers and sends in documents and the agency receives and processes them, the applicant can enroll in Medicaid, CHIP, or a marketplace plan if he meets all other eligibility requirements during a “reasonable opportunity period” or “inconsistency period.”

Why are some lawfully present immigrants who are eligible for subsidies not able to immediately enroll in subsidized coverage?

Lawfully present immigrants who have income within the Medicaid eligibility range but are ineligible for Medicaid due to their immigration status can qualify for premium tax credits and cost-sharing reductions even if their income falls below the poverty line.  (Generally, consumers must have income between 100-400 percent of the poverty line to qualify for premium tax credits and cost sharing reductions.)  However, Healthcare.gov has system limitations that can result in an incorrect eligibility determination for some of these individuals.

If Healthcare.gov can instantly verify that a consumer is lawfully present but ineligible for Medicaid because of his immigration status, the applicant should receive the correct determination of eligibility for subsidies.

If Healthcare.gov cannot instantly verify that the consumer’s immigration status makes him ineligible for Medicaid, then the consumer will receive an incorrect eligibility determination for subsidies.  This is because Healthcare.gov will assume the consumer is eligible for Medicaid based on immigration status until the consumer provides proof of his immigration status, which shows he is ineligible for Medicaid. One of two erroneous determinations will occur:

• Healthcare.gov incorrectly assesses or determines he is eligible for Medicaid if the consumer otherwise appears to meet the income and other applicable requirements for Medicaid eligibility.
• Healthcare.gov incorrectly determines he is ineligible for marketplace subsidies and he is treated as if he were in the coverage gap.   This can occur in states that have not expanded Medicaid.  If the consumer does not meet the Medicaid income or other applicable requirement and his income is below the poverty line, Healthcare.gov assumes the consumer is in the coverage gap and does not send his case file to Medicaid.  These individuals are told they are only eligible to purchase a marketplace plan at full cost —without subsidies but that they may qualify for help paying for coverage but must turn in documents to prove their immigration status.

What steps need to be taken to get the correct determination for individuals incorrectly assessed or determined eligible for Medicaid? 

Consumers must be determined ineligible for Medicaid based on their immigration status before they can get the correct eligibility determination for marketplace subsidies.  When Healthcare.gov incorrectly assesses or determines individuals as eligible for Medicaid, it sends the individual’s case file to the state Medicaid agency.  The Medicaid agency will ask the consumer to provide proof of his immigration status.  After the consumer provides proof and is denied Medicaid based on his immigration status, he will be referred back to Healthcare.gov and instructed to update his application to indicate he has been denied eligibility for Medicaid based on immigration status.

After a consumer notes on the application that he has been denied Medicaid due to immigration status, he should receive a correct determination of eligibility for subsidies.

What steps need to be taken to get the correct determination for individuals incorrectly determined ineligible for subsidies and treated as if they were in the coverage gap? 

These consumers must also be determined ineligible for Medicaid based on their immigration status before they can get the correct eligibility determination for marketplace subsidies.  Their eligibility determination notice will say they are not eligible for subsidies and are eligible for an exemption from the requirement to have health insurance, and that they may qualify subsidies but they must submit documents to prove their immigration status to make that determination.  When the marketplace receives and processes the documents, eligible consumers are sent a corrected eligibility determination notice that includes information on eligibility for subsidies, access to a special enrollment period, and instructions to return to Healthcare.gov to select a plan.

Are there any alternative steps individuals can take to get the correct eligibility determination? 

In some cases consumers can get a Medicaid denial due to immigration status more quickly by applying for Medicaid directly through the state Medicaid agency. Once denied Medicaid eligibility based on immigration status by the state agency, consumers can return to Healthcare.gov and indicate they have been denied Medicaid due to immigration status.

View all key facts