CMS Revives ACA Subsidy Verification Matching Program
Published Date: 11/18/2025
Notice
Summary
The Centers for Medicare & Medicaid Services (CMS) is restarting a program that helps states check who qualifies for health subsidies under the Affordable Care Act. This program will run for about 18 months starting around October 2025, with a chance to extend for another year. If you’re involved with state health programs, this means your info will be matched carefully to make sure benefits go to the right people, and you can comment on the plan until December 18, 2025.
Analyzed Economic Effects
5 provisions identified: 5 benefits, 0 costs, 0 mixed.
CMS restarts eligibility matching
CMS re-established a data-matching program to verify who qualifies for state health subsidy programs under the Affordable Care Act. The program will run for an initial term of about 18 months (approximately October 2025 to March 2027), may be renewed for up to one additional year, and the public comment deadline is December 18, 2025.
Your tax and identity records will be checked
The program will use and exchange records such as Social Security Number, name, date of birth, income based on Federal Tax Information (FTI), Title II benefits, citizenship/immigration status, incarceration status, and death indicators to verify applicants' eligibility for subsidies and minimum essential coverage.
States and CMS will share enrollment info
CMS will share information with State-Based Administering Entities (AEs) — and AEs will share among themselves — through a CMS data services hub to verify whether applicants or enrollees are currently eligible for or enrolled in Medicaid/CHIP, with the stated purpose of avoiding dual enrollment.
Privacy Act limits and verification protections
Under the Privacy Act, agencies must notify individuals that their information may be verified by matching, enter into a written matching agreement, report to Congress and OMB, and verify match findings before suspending, terminating, reducing, or finally denying benefits or taking other adverse actions.
Which jurisdictions participate now
Currently each of the 50 states, the District of Columbia, and Puerto Rico has one or more State-Based Administering Entities participating in the matching program; other U.S. territories may eventually participate.
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