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HHS and CMS propose annual eligibility checks for ACA Marketplace coverage: what changes in 2028

HHS and CMS propose that ACA Marketplace enrollees confirm their eligibility every year before advance premium tax credits and cost-sharing reductions renew. Curious what that means for your program? We built RuleLens, a free workspace that walks through the proposed rule section by section. Open RuleLens.

What's happening

On October 27, 2026, the Centers for Medicare & Medicaid Services (CMS), part of the Department of Health and Human Services (HHS), published a proposed rule, "Patient Protection and Affordable Care Act, Exchange Pre-Eligibility Verification" (45 CFR Part 155). It would have ACA Marketplace enrollees confirm their eligibility information each year before financial help (advance premium tax credits and cost-sharing reductions) is renewed, and it would give marketplaces an optional window to verify eligibility before open enrollment. Most of it would apply starting with plan year 2028. Public comments are due November 27, 2026.

What's in RuleLens

  • Overview. The proposal in plain language, piece by piece.
  • Timeline. Key dates, from publication to the proposed start dates.
  • Document map and full text. Find the section you need without reading the whole notice.
  • Public comments. Posted comments, kept separate from the explanation.
  • Sources. Links to the official documents throughout.

Who it's for

Federal and state program teams, marketplaces, enrollment partners, and the contractors who build and support eligibility systems. If a rule like this lands on your program, the work is in the details: application changes, notices, document review, timing, and staffing.

RuleLens is an independent explainer and a saved snapshot of the notice, not a government website or legal advice. It doesn’t update on its own. Read the official documents for exact requirements.

We built it the way we work on any program: read the source, map what changes, and show what each group has to do. If your team is working through a rule change, we're happy to talk.

Interested in our services, or in partnering?

Send a short note about your program and what needs analysis. We'll set up a short call.