ACA Marketplace Application Best Practices — Frequently Asked Questions

This article covers best practices for completing Marketplace applications accurately, including how to handle Social Security Numbers on EDE applications, how to avoid creating duplicate applications, and how income below 100% of the federal poverty level affects eligibility.

If an applicant has a Social Security Number (SSN), it must be entered on the Marketplace application. CMS requires Enhanced Direct Enrollment (EDE) websites to display additional language with the SSN question to clarify when it is permissible to check the box for "doesn't have an SSN." That box may only be selected if the applicant attests they have never been issued an SSN by the Social Security Administration.

If you select that box, a follow-up question will appear asking you to confirm the applicant does not have an SSN, along with a reminder of the potential consequences for providing inaccurate information to the Marketplace.

Marketplace-registered agents and brokers must assist all consumers seeking Marketplace coverage with completing a Marketplace application and reviewing their eligibility results, regardless of whether the consumer has an SSN. If an applicant's SSN is not included on the application, the consumer will receive a Data Matching Issue (DMI) and will be required to submit additional documentation to the Marketplace. An unresolved DMI puts the consumer at risk of losing coverage or financial assistance, and puts you at risk of losing compensation. You or the consumer can update the application to include the SSN to resolve the DMI instead of submitting documents.

Before taking any other action, obtain consent from the consumer and perform a person search to check whether the consumer already has a Marketplace application for the current coverage year. A person search can be conducted using the consumer's name, date of birth (DOB), or Social Security Number (SSN).

If one search input does not return an existing application, always try another — such as the SSN if you have not already tried it, or variations of the consumer's first or last name. A typo in a consumer's name can produce incorrect search results. Always confirm with the consumer that their first name, last name, middle initials, and date of birth are spelled and entered correctly.

If an existing application is found, update it. Do not create a new application. A duplicate application for one household member can cause all other members of the existing policy to lose coverage and tax credits, and can result in you losing commissions if consumers are inadvertently terminated from coverage.

When a consumer applies for help paying for Marketplace coverage, the Marketplace calculates their household income using Modified Adjusted Gross Income (MAGI) methodology. This dollar amount is then converted to a percentage of the Federal Poverty Level (FPL) to determine eligibility for Advance Payments of the Premium Tax Credit (APTC), cost-sharing reductions (CSRs), and Medicaid/Children's Health Insurance Program (CHIP).

In cases where a consumer's annual income is below 100% of the FPL but their current monthly income is too high for Medicaid eligibility, state Medicaid/CHIP agencies are required to use the household's projected annual income to determine eligibility. The consumer may need to provide supporting evidence, such as a signed employment contract or a documented history of predictable income fluctuations.

If the state Medicaid/CHIP agency determines the consumer is not eligible for Medicaid or CHIP based on projected annual income, the consumer may then be eligible to enroll in a Marketplace qualified health plan (QHP) with financial assistance, if otherwise eligible.

If you have any questions please contact Producer Support. Producer Support is available by phone at (866) 568-9649, by email at [email protected], or by chat directly from your MyMFG account.