Medicare Fixes Its Own Messy Subsidy Matching Notice
Published Date: 11/28/2025
Notice
Summary
The Centers for Medicare & Medicaid Services fixed a previous notice about a program that helps states check who can get health subsidies under the Affordable Care Act. They corrected confusing language, wrong dates, and made the summary easier to understand. This update affects state agencies and helps make sure people get the right health benefits on time, with no extra costs involved.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 0 costs, 1 mixed.
CMS–State Data Match for ACA Subsidies
If you apply for state health subsidies under the Affordable Care Act through a state-based marketplace, CMS will share data with State-Based Administering Entities (AEs) to determine your eligibility and to avoid dual enrollments. The re-established matching program has a public comment deadline of December 29, 2025, will not begin sooner than 30 days after publication, and will run an initial 18-month term (approximately January 2026 to July 2027).
What Records CMS and States Will Share
The matching program will share specified categories of records between CMS and State AEs, including identifying records; minimum essential coverage period records; Federal Tax Information (FTI) (household income and family size); citizenship status; birth and death information; disability coverage and income information; and imprisonment status. Data elements noted include Social Security Number (if applicable), name, date of birth, validation of SSN, verification of citizenship or immigration status, incarceration status, eligibility/enrollment in certain types of minimum essential coverage, income based on FTI and Title II benefits and current income sources, quarters of coverage, and a death indicator.
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