UPDATE: Marketplace Guidance for Noncitizens Applying for 2027 Coverage
As agents prepare for Plan Year 2027 Open Enrollment, CMS has provided additional guidance regarding noncitizens applying for Marketplace coverage and financial assistance.
These updates are especially important when helping mixed-status families or clients who have employment authorization documents.
Noncitizen Parents Can Apply for Citizen Dependents
Noncitizen family members may apply for Marketplace coverage and APTC/financial assistance on behalf of citizen or otherwise lawfully present dependent family members.
For agents assisting clients in State-Based Exchanges (SBEs), specific application instructions may vary by state. Contact the appropriate SBE for state-specific guidance.
Important Change to Financial Assistance for 2027
Beginning with Plan Year 2027, eligibility for Marketplace financial assistance—including:
Advance Premium Tax Credits (APTC)
Income-based Cost-Sharing Reductions (CSRs)
will be limited to U.S. citizens, U.S. nationals, and eligible noncitizens, provided all other eligibility requirements are met.
Who Is Considered an “Eligible Noncitizen”?
For purposes of financial assistance, eligible noncitizens are limited to:
Lawful Permanent Residents (LPRs / green card holders)
Cuban or Haitian Entrants
COFA migrants — individuals lawfully residing under a Compact of Free Association
Employment Authorization Does Not Automatically Mean Eligibility for APTC/CSRs
An Employment Authorization Document (EAD/Form I-766) allows an individual to legally work in the United States, but having an EAD does not by itself establish eligibility for Marketplace financial assistance.
Lawfully present noncitizens who do not fall within the eligible noncitizen categories above may still enroll in a Qualified Health Plan (QHP) through the Marketplace, but beginning in Plan Year 2027, they will not be eligible for APTC or CSRs and would pay the full premium.
What Agents Should Know for 2027
When assisting a noncitizen client:
Determine whether the client meets the eligible noncitizen definition for financial assistance.
If applicable, clients may use information from their EAD/Form I-766 as part of the eligibility application.
Applicants will be asked to attest to their immigration status when applying for financial assistance.
Encourage clients to provide as much information as possible from their immigration documents so the Marketplace can determine and verify eligibility.
Have Questions?
For additional guidance or questions regarding noncitizen eligibility and Marketplace financial assistance, contact the CMS FFM Producer & Assister Help Desk:
For additional assistance, contact The Brokerage Inc. Health team at [email protected] or, call 469-635-6771.
Prepare now for Plan Year 2027 Open Enrollment and make sure you understand how these changes may affect the clients you serve.
For agent and broker information. Please refer to CMS and applicable State-Based Exchange guidance for the most current requirements.
