Quick Reference

ACA Knowledge Guide

First American Insurance
Top 5 Questions per Chapter — Fast Answers for Agents
www.firstamericanmedicare.comCharles@firstamericanmedicare.com✆ 888 840 5814
110Q&As
22Chapters
Top 5Per Chapter
First American Insurance
First American Insurance — Quick Reference
Quick Reference

How to Use This Guide

This Quick Reference pulls the top 5 most essential Q&As from each of the 22 chapters. Use it for fast answers during calls or client meetings.

For the complete answer library with all 550 entries, refer to the full eBook.

Tip: Each answer includes escalation triggers so you know exactly when to transfer to a specialist.
Contents

Table of Contents

Chapter 1: ACA Basics

1
Basics

What is the Affordable Care Act?

Quick Answer

The ACA is a federal law from 2010 that made it illegal for insurance companies to deny you coverage because of a health condition, and created a marketplace where you can shop for health insurance and possibly get financial help to pay for it.

Details

The Affordable Care Act (ACA), signed into law in March 2010, is the federal health reform law that established consumer protections, created the Health Insurance Marketplace, expanded Medicaid, and introduced financial assistance for eligible individuals and families.

Exceptions: Grandfathered and grandmothered plans pre-dating 2010 are not required to meet all ACA rules. Short-term, limited-duration plans and fixed-indemnity plans are not ACA-compliant. Some self-insured employer plans have partial exemptions.
Escalate If: A client asks about a specific plan's ACA compliance status, has a grandfathered plan, or is comparing ACA coverage to non-compliant alternatives.
2
Marketplace

What is Marketplace health insurance?

Quick Answer

Marketplace insurance is health coverage you can shop for and buy at HealthCare.gov or your state's exchange website. Depending on your income, you may qualify for financial help that makes it much more affordable.

Details

Marketplace health insurance is ACA-compliant coverage sold through HealthCare.gov (for most states) or a state-based exchange, where eligible applicants can compare plans, enroll, and apply for premium tax credits or cost-sharing reductions.

Exceptions: Plans sold directly by insurers outside the Marketplace (off-exchange) are ACA-compliant but cannot receive premium tax credits. COBRA, short-term plans, and farm bureau plans are not Marketplace plans.
Escalate If: A client is confused about whether they are enrolled on-Marketplace or off-Marketplace, which affects subsidy eligibility.
3
Eligibility

Who is ACA coverage designed for?

Quick Answer

Marketplace coverage is for people who need to buy their own health insurance—like those who are self-employed, between jobs, or whose job doesn't offer affordable coverage.

Details

ACA Marketplace coverage is designed for U.S. citizens, nationals, and lawfully present immigrants who are not incarcerated, are not eligible for government-sponsored coverage like Medicare or Medicaid, and need individual or family health insurance.

Exceptions: Immigrants with Deferred Action for Childhood Arrivals (DACA) status were made eligible in 2024 but that rule was reversed as of August 25, 2025; DACA recipients are no longer eligible for Marketplace coverage in 2026. Undocumented immigrants cannot enroll.
Escalate If: A client has uncertain immigration status, is near the Medicaid/Marketplace income boundary, or has Medicare coverage and wants to know about Marketplace options.
4
Compliance

What does ACA-compliant coverage mean?

Quick Answer

An ACA-compliant plan follows the rules the law set for health insurance—it has to cover essential services, can't turn you away for health reasons, and can't charge you unlimited amounts out of pocket.

Details

ACA-compliant coverage is a health plan that meets all federal requirements under the Affordable Care Act, including covering the 10 essential health benefits, following community rating rules, and complying with consumer protections like guaranteed issue and no pre-existing condition exclusions.

Exceptions: Short-term health plans, fixed-indemnity plans, farm bureau plans, health care sharing ministries, and pre-ACA grandfathered plans do not meet ACA compliance standards and lack its full protections.
Escalate If: A client is considering a non-ACA-compliant alternative (like a short-term plan) and needs to understand what protections they would lose.
5
Plan Types

How is ACA coverage different from short-term insurance?

Quick Answer

ACA plans must cover your pre-existing conditions and all major medical services. Short-term plans are cheaper but can deny you coverage, exclude your health conditions, and leave you with large unexpected bills.

Details

ACA coverage must cover all 10 essential health benefits, cannot exclude pre-existing conditions, and has no lifetime dollar limits; short-term insurance can deny enrollment based on health, exclude pre-existing conditions, skip essential benefits, and leave enrollees with uncapped out-of-pocket costs.

Exceptions: Some states (e.g., California, New York) have banned or heavily restricted short-term plans. In those states short-term plans may not be available at all.
Escalate If: A client is weighing an ACA plan against a short-term plan and has a pre-existing condition, prescription drug needs, or is likely to use significant health care.

Chapter 2: Eligibility Residency

1
Who Apply

Who can apply for Marketplace coverage?

Quick Answer

Anyone who lives in the U.S., is a citizen or legally present immigrant, and isn't on Medicare can apply for Marketplace coverage—even if your income is low or high.

Details

U.S. citizens and nationals, and lawfully present immigrants who live in the Marketplace service area, are not incarcerated, and are not enrolled in Medicare can apply for Marketplace coverage.

Exceptions: DACA recipients became ineligible for Marketplace coverage as of August 25, 2025. Undocumented immigrants cannot enroll. People enrolled in Medicare cannot purchase subsidized Marketplace plans.
Escalate If: A client has uncertain immigration status, is near the Medicaid threshold, or is a DACA recipient who was previously enrolled.
2
Citizenship

Do I have to be a U.S. citizen to enroll?

Quick Answer

You don't have to be a citizen to enroll. Legal immigrants with valid immigration status can buy Marketplace coverage. Undocumented immigrants cannot.

Details

No—U.S. citizenship is not required. U.S. citizens, nationals, and lawfully present immigrants are all eligible to apply for Marketplace coverage. Undocumented immigrants are not eligible.

Exceptions: DACA recipients lost Marketplace eligibility on August 25, 2025. Pending legislative changes could restrict subsidy eligibility for some immigrant categories. Certain visa types may have documentation verification challenges.
Escalate If: A client has a non-standard or complex immigration status, is a DACA recipient, or needs help navigating documentation verification issues.
3
Immigration

Can lawfully present immigrants get ACA coverage?

Quick Answer

Yes, most legal immigrants can sign up for Marketplace health coverage and may qualify for financial help. You'll need to provide documents proving your immigration status.

Details

Yes. Lawfully present immigrants—including green card holders, refugees, asylees, TPS holders, and valid visa holders—can enroll in Marketplace plans. They may also qualify for premium tax credits and cost-sharing reductions.

Exceptions: DACA recipients are ineligible as of August 25, 2025. Undocumented immigrants are not eligible. Immigrants subject to the 5-year Medicaid bar can still use the Marketplace.
Escalate If: A client has a complex or non-standard immigration status, is a DACA recipient, is a mixed-status household, or is an immigrant near the Medicaid/Marketplace income threshold.
4
State Variation

Do I have to live in the state where I apply?

Quick Answer

Yes—you must live in the state where you're applying. Each Marketplace is state-specific, so you can only buy a plan that covers where you live.

Details

Yes. You must live in the state where you apply and purchase Marketplace coverage. You cannot enroll in a plan from another state, and you must reside within the plan's service area.

Exceptions: Students living away from home for school may be able to enroll in either their home state or school state Marketplace, depending on their situation. Seasonal or dual-state workers should apply in their state of primary residence.
Escalate If: A client has a complex residency situation—such as splitting time between two states or a student living away from home—that makes the 'primary state of residence' determination unclear.
5
Life Changes

Can I enroll if I recently moved?

Quick Answer

Yes, moving to a new area gives you 60 days to sign up for a health plan. You don't have to wait for open enrollment—your move is your qualifying reason to enroll.

Details

Yes. A permanent move to a new coverage area triggers a Special Enrollment Period, giving you 60 days to enroll in a Marketplace plan in your new location.

Exceptions: Temporary moves (vacation, short-term work assignments) do not qualify. Moving within the same county and coverage area may not trigger an SEP if your existing plan is still available.
Escalate If: A client has already moved and their old coverage has ended, or the move spans multiple states and involves a state-based Marketplace.

Chapter 3: Enrollment Periods

1
Open Enrollment

What is Open Enrollment for ACA plans?

Quick Answer

Open Enrollment is the annual window to sign up for health insurance. For 2026 plans, it was November 1 through mid-January. If you enroll by December 15, your coverage starts January 1.

Details

Open Enrollment is the annual window during which anyone eligible for Marketplace coverage can enroll in or change plans for the next coverage year. For 2026 coverage, the Open Enrollment Period was November 1–January 15, 2026, on HealthCare.gov.

Exceptions: State-based Marketplaces had different end dates than HealthCare.gov. Medicaid/CHIP enrollment is open year-round for those who qualify.
Escalate If: A client believes they missed Open Enrollment and needs to determine if they qualify for a Special Enrollment Period.
2
Plan Selection

When can I enroll in a Marketplace plan?

Quick Answer

You can enroll during Open Enrollment each fall/winter, or at any time if something big happens in your life—like losing your job-based coverage or getting married.

Details

You can enroll in a Marketplace plan during the annual Open Enrollment Period (November–January for federal Marketplace), or outside OEP if you have a qualifying life event that triggers a Special Enrollment Period.

Exceptions: Medicaid and CHIP can be enrolled in anytime. Some SBE states have broader SEP triggers. Native Americans and Alaska Natives can enroll at any time during the year.
Escalate If: A client wants to enroll outside of Open Enrollment and needs help determining whether their life event qualifies for a Special Enrollment Period.
3
Open Enrollment

Can I enroll outside Open Enrollment?

Quick Answer

Yes, if something major happens in your life—like losing your health insurance, moving, or having a baby—you get a 60-day window to sign up for a Marketplace plan even when it's not open enrollment season.

Details

Yes, you can enroll outside Open Enrollment if you have a qualifying life event that triggers a Special Enrollment Period. Without a qualifying event, you must wait for the next Open Enrollment Period.

Exceptions: Simply wanting coverage, or voluntarily dropping other coverage, does not qualify for an SEP. SEP documentation requirements must be met to complete enrollment.
Escalate If: A client believes they have a qualifying event but is unsure, or their SEP claim has been denied by the Marketplace.
4
Special Enrollment

What is a Special Enrollment Period?

Quick Answer

An SEP is your window to sign up for health insurance after something big changes in your life. It usually lasts 60 days from the day the qualifying event happened.

Details

A Special Enrollment Period (SEP) is a limited time window—typically 60 days—to enroll in or change Marketplace coverage outside of Open Enrollment, triggered by a qualifying life event such as losing coverage, getting married, or having a baby.

Exceptions: The SEP for loss of Medicaid is 90 days (not the standard 60). Exceptional circumstance SEPs may have different durations.
Escalate If: A client's SEP window has expired but they still need coverage, or the SEP was denied despite a legitimate qualifying event.
5
Special Enrollment

How long do I have to use a Special Enrollment Period?

Quick Answer

You have 60 days from your qualifying event to sign up. If you lost Medicaid, you get 90 days. Don't wait too long—if you miss the window, you may have to wait until next open enrollment.

Details

Generally 60 days from the qualifying life event—either to enroll or make a plan change. For loss of Medicaid or CHIP, the SEP window is 90 days. You can also start some SEPs up to 60 days before a qualifying event.

Exceptions: Exceptional circumstance SEPs may be longer (up to a year in some cases). Native Americans and Alaska Natives can enroll at any time without using a 60-day window.
Escalate If: A client has missed their SEP window and needs coverage—exploring exceptional circumstance SEP options or state-specific provisions is warranted.

Chapter 4: Market App

1
Apply Aca

How do I apply for ACA Marketplace coverage?

Quick Answer

You can apply online at HealthCare.gov (or your state's exchange site), by phone, or with help from a free licensed agent or local enrollment counselor.

Details

You can apply for ACA Marketplace coverage at HealthCare.gov (for most states), at your state's exchange website, by phone (1-800-318-2596), or with the help of a licensed agent, broker, or navigator.

Exceptions: Some states have their own Marketplace websites with different application processes. Paper applications are available for those who cannot apply online or by phone.
Escalate If: A client is having technical difficulties submitting an application, receives an error during the eligibility determination, or their application has been pending for more than a few days without resolution.
2
Application

What information is needed on the application?

Quick Answer

The application asks who's in your family, everyone's income, your Social Security numbers, and whether anyone is offered health insurance at work. Gathering this information before you start will make it faster.

Details

The application asks for: Social Security numbers (or immigration document numbers), dates of birth, citizenship/immigration status, household members and their relationship to you, projected annual income for all household members, and information about any other health coverage available.

Exceptions: Mixed-status households where some members are undocumented: undocumented household members' income counts toward the household total, but they are not eligible for coverage themselves.
Escalate If: A client has complex income situations (multiple businesses, rental properties, significant investment income, recent life changes) that make MAGI estimation difficult.
3
Need Social

Do I need Social Security numbers for everyone applying?

Quick Answer

Yes, you need Social Security numbers for anyone in your household who is applying for coverage and is a U.S. citizen. If a family member is an immigrant, they use their immigration document number instead.

Details

You need Social Security numbers for all household members who are applying for coverage and who are U.S. citizens or nationals. Lawfully present immigrants without SSNs provide immigration document numbers instead.

Exceptions: Non-applying household members (such as an undocumented parent) do not need to provide an SSN. Household members who are applying for children-only coverage under CHIP may have different requirements.
Escalate If: A household member applying for coverage cannot provide an SSN or immigration document number due to a recent move, lost documents, or pending immigration case.
4
Agent Help

Can I apply online, by phone, or with an agent?

Quick Answer

Yes—you can apply online yourself, call the Marketplace directly, or work with a free local helper or licensed insurance agent. All of these are valid ways to get enrolled.

Details

Yes. You can apply online at HealthCare.gov or your state Marketplace website, by calling the Marketplace call center (1-800-318-2596), or with in-person help from a licensed agent, broker, or free navigator/enrollment assister.

Exceptions: Paper applications take longer to process and may result in delayed coverage. Phone applications may have longer wait times during peak Open Enrollment periods.
Escalate If: A client needs in-person assistance but there are no navigators in their area, or they have language barriers that require a specific interpreter.
5
Application

What household members must be listed on the application?

Quick Answer

Everyone in your tax household should be listed, even if some people already have coverage or don't want to enroll. Their income counts toward your household total, which affects how much financial help you qualify for.

Details

You must list all members of your tax household on the application—including tax dependents—even if some will not be enrolling in a Marketplace plan. Their income and eligibility affects your subsidy calculation.

Exceptions: Non-tax-dependent household members (such as a non-dependent domestic partner, or an undocumented family member) are not included in the Marketplace household, though undocumented members' income does count.
Escalate If: A household has complex composition issues—such as multiple tax filers in the same dwelling, or uncertainty about who counts as a dependent—that affects subsidy calculations.

Chapter 5: Premium Tax Credits

1
Tax Reconciliation

What is the premium tax credit?

Quick Answer

The premium tax credit is a government subsidy that reduces your monthly health insurance bill. In 2026, it's only available if your household income is between about $15,960 and $62,600 for a single person.

Details

The premium tax credit (PTC) is a federal tax credit that helps eligible people and families pay for health insurance purchased through the Marketplace. For 2026, it is available only to households with income between 100% and 400% FPL.

Exceptions: Lawfully present immigrants below 100% FPL who are not eligible for Medicaid due to the 5-year bar can qualify for PTCs even below the 100% FPL threshold. People offered employer coverage that is 'affordable' are generally not eligible for PTCs.
Escalate If: A client received APTC in 2025 under the enhanced rules and needs help understanding 2026 reconciliation differences; a client believes their 2026 subsidy amount is wrong; or a client needs tax advice on Form 8962 reconciliation.
2
Tax Reconciliation

Who can qualify for premium tax credits?

Quick Answer

In 2026, you can only get a subsidy if your income is between about $15,960 and $62,600 (single person), you buy insurance through the Marketplace, and you don't have access to affordable job-based or government health insurance.

Details

To qualify for the 2026 premium tax credit, a household must: (1) have income between 100%–400% FPL, (2) enroll in a Marketplace plan, (3) not be eligible for affordable employer coverage or government programs like Medicaid or Medicare, and (4) file a joint return if married.

Exceptions: Lawfully present immigrants below 100% FPL who can't get Medicaid due to the 5-year waiting period may still qualify. Victims of domestic violence may file separately and still claim the credit. DACA recipients are no longer eligible for Marketplace coverage as of August 2025.
Escalate If: A client's income is near the 400% FPL cliff and they need to understand their exact eligibility cutoff; a married couple is filing separately and wants to know if exceptions apply; immigration status questions arise.
3
Tax Reconciliation

How does the premium tax credit lower my premium?

Quick Answer

The Marketplace calculates the gap between the cost of the standard Silver plan and what you're expected to pay based on your income. That gap becomes your monthly subsidy, which is sent directly to your insurance company.

Details

The premium tax credit lowers your monthly premium by calculating the difference between the benchmark plan cost and your required contribution percentage. The credit is applied directly to your insurer each month when taken as APTC.

Exceptions: The credit applies to the plan premium, not to cost-sharing (deductibles, copays). Choosing a plan with a premium lower than the credit amount results in a $0 net premium but the credit cannot exceed the actual plan premium.
Escalate If: A client's calculated subsidy amount does not match what HealthCare.gov shows; a client chose a plan and the net premium seems incorrect; or a client needs help understanding why their subsidy differs from last year's due to the 2026 cliff restoration.
4
Subsidies

Can I choose to take less subsidy than I qualify for?

Quick Answer

Yes, you can take a smaller subsidy each month or skip monthly payments altogether and claim the credit at tax time. This can protect you from having to pay money back if your income turns out to be higher than you expected.

Details

Yes. You can choose to receive less advance premium tax credit than you qualify for—or none at all—and claim the remainder when you file your taxes. This reduces repayment risk if your income ends up higher than estimated.

Exceptions: There is no mechanism to take more APTC than you qualify for based on your income estimate—the Marketplace will not approve an APTC amount above the calculated credit.
Escalate If: A client wants to zero out their APTC mid-year and needs to understand how to update their application; a client owes significant excess APTC from a prior year and needs tax advice.
5
Subsidies

Can I take all of the subsidy in advance?

Quick Answer

Yes, you can take the full subsidy monthly so you pay less each month. Just be aware that if your income ends up being higher than you reported, you'll need to pay some of it back when you do your taxes.

Details

Yes. You can elect to have your full calculated advance premium tax credit applied each month to reduce your monthly premium. The full credit is paid to your insurer monthly; you reconcile the actual amount on your tax return.

Exceptions: Taking the full APTC monthly carries repayment risk. In 2026, exceeding 400% FPL means full repayment of all APTC received—there is no cap above that threshold.
Escalate If: A client has received the full APTC for several months but had a significant income increase—they should update their Marketplace application immediately to reduce repayment risk at tax time.

Chapter 6: CSR Reductions

1
Cost-Sharing Reduction

What is a cost-sharing reduction?

Quick Answer

A cost-sharing reduction (CSR) is extra government help that reduces what you pay when you actually use your health insurance—like your deductible and copays. You have to pick a Silver plan through the Marketplace to get this benefit.

Details

A cost-sharing reduction (CSR) is a federal benefit that reduces the deductibles, copays, coinsurance, and out-of-pocket maximums for eligible Marketplace enrollees. CSRs are only available on Silver plans purchased through the Marketplace.

Exceptions: CSRs are ONLY available on Silver plans purchased through the Marketplace. Choosing Bronze, Gold, or Platinum—or buying off-Marketplace—forfeits CSR eligibility even if income qualifies. American Indian/Alaska Native members may receive CSRs on any metal-level plan.
Escalate If: A client believes they should qualify for CSRs but the Marketplace did not offer a CSR-enhanced plan; a client selected a non-Silver plan and wants to know if they can get CSR; or a client is an American Indian/Alaska Native seeking guidance on their special CSR rights.
2
Cost-Sharing Reduction

Who can qualify for cost-sharing reductions?

Quick Answer

In 2026, you qualify for CSRs if your income is between about $15,960 and $39,900 (single person), you pick a Silver plan on the Marketplace, and you're not eligible for Medicaid or affordable job-based insurance.

Details

To qualify for cost-sharing reductions in 2026, you must: (1) have household income between 100% and 250% FPL, (2) enroll in a Silver plan through the official Marketplace, and (3) be eligible for premium tax credits.

Exceptions: American Indians and Alaska Natives have special CSR rights: zero cost-sharing on any Marketplace plan regardless of income level. Lawfully present immigrants below 100% FPL who can't get Medicaid (5-year bar) may qualify. Above 250% FPL, CSRs are not available—though premium tax credits continue through 400% FPL.
Escalate If: A client is near the 250% FPL threshold and wants to understand the exact cutoff; a client in a non-expansion state with very low income is unsure whether they qualify; or an AI/AN client needs guidance on their special cost-sharing protections.
3
Cost-Sharing Reduction

Do cost-sharing reductions work on every metal level?

Quick Answer

No—CSRs only work if you pick a Silver plan through the Marketplace. If you choose any other plan type, you won't get the extra help with your deductibles and copays even if your income qualifies.

Details

No. Cost-sharing reductions only work on Silver plans purchased through the Marketplace. Choosing Bronze, Gold, Platinum, or Catastrophic plans—even through the Marketplace—makes you ineligible for CSRs, regardless of income.

Exceptions: American Indians and Alaska Natives are the key exception—they can receive zero cost-sharing on any metal-level plan. All other CSR-eligible enrollees must select Silver plans through the Marketplace.
Escalate If: A client selected a non-Silver plan and later realized they were CSR-eligible—during Open Enrollment or an SEP, they can be guided to switch to a Silver plan to access CSRs.
4
Cost-Sharing Reduction

Why are cost-sharing reductions usually tied to Silver plans?

Quick Answer

The law was designed so Silver plans serve as the standard reference point for both subsidies and extra cost-sharing help. It's the 'middle' metal level that's meant to be the standard choice for most people getting financial help.

Details

CSRs are tied to Silver plans by statute. Congress designed the ACA so that Silver plans serve as the benchmark for subsidy calculations AND the vehicle for cost-sharing reductions, creating a consistent 'middle tier' that balances premiums and cost-sharing.

Exceptions: Due to silver loading, in many markets the Gold plan premium is close to or lower than Silver after applying the PTC. CSR-eligible consumers should compare actual net costs across all plans, not just Silver plans.
Escalate If: A client in a heavily silver-loaded market is trying to determine whether Silver with CSR or Gold without CSR is the better value—this requires a detailed cost analysis based on their specific plan options.
5
Cost-Sharing Reduction

How do cost-sharing reductions help with deductibles and copays?

Quick Answer

CSRs dramatically lower your costs when you use care—like your deductible, copays, and the most you'll pay in a year. For people with income below 150% of the poverty level, the Silver plan can work almost like Platinum coverage, but at a much lower cost.

Details

CSRs increase the actuarial value of Silver plans, which directly lowers deductibles, copayments, and coinsurance amounts. The specific dollar reductions vary by plan and carrier, but CSR Silver plans are required to hit specific AV targets.

Exceptions: The exact deductibles and copays vary by carrier plan design within each AV tier. Insurers have some flexibility in how they achieve the required AV. Always review the specific Summary of Benefits and Coverage (SBC) for the plan being considered.
Escalate If: A client believes a specific plan's cost-sharing is not consistent with their CSR tier (e.g., their CSR Silver has a very high deductible that seems inconsistent with 87% AV)—this may be a plan documentation error or a plan design question.

Chapter 7: Income Household

1
Subsidies

What income counts for ACA subsidies?

Quick Answer

The Marketplace counts most types of income — wages, self-employment, Social Security, unemployment, and investment income — but not child support or SSI. You must report your best estimate of this year's total household income.

Details

For ACA subsidies, income means Modified Adjusted Gross Income (MAGI) — essentially your adjusted gross income plus certain add-backs like tax-exempt interest and non-taxable Social Security benefits.

Exceptions: Lawfully present immigrants below 100% FPL who are ineligible for Medicaid (e.g., due to the 5-year waiting period) can still qualify for subsidies. Roth IRA withdrawals do not count. Child support received is excluded.
Escalate If: The client has complex income sources (partnerships, trusts, foreign income, business losses), a recent major income change, or has already received APTC and their actual income differed significantly from estimates.
2
Household

What does household mean for Marketplace purposes?

Quick Answer

Your 'household' for health insurance purposes is the same group of people you put on your tax return — you, your spouse, and any dependents you claim.

Details

For Marketplace purposes, 'household' means the people you list on your federal tax return — yourself, your spouse if filing jointly, and anyone you claim as a tax dependent.

Exceptions: Divorced parents who alternate claiming a child may have different household sizes in alternating years. Married couples who file separately generally cannot claim premium tax credits. Non-married partners living together are not in the same household unless they claim each other as dependents.
Escalate If: The client has a complex family situation — divorce, separated spouses, multiple households, unmarried partners, or custody disputes — that creates ambiguity about who belongs in their tax household.
3
Tax Reconciliation

Why does the Marketplace ask about tax filing?

Quick Answer

The Marketplace subsidizes your premium based on your estimated income. At tax time, the IRS checks whether the subsidy matched your real income — if you made more than expected, you may owe some money back.

Details

The Marketplace asks about tax filing because premium tax credits are reconciled on your federal tax return — the subsidy you receive during the year must match what your actual annual income supports.

Exceptions: Individuals who do not file taxes due to low income may still be eligible for Medicaid but generally cannot receive premium tax credits. Some people with no filing requirement received APTC and must still file Form 8962.
Escalate If: The client received APTC and had a large income swing during the year, or they did not file a prior-year return and are now blocked from receiving APTC, or they owe a significant repayment amount.
4
MAGI

What is modified adjusted gross income for ACA?

Quick Answer

MAGI is basically your taxable income plus a few extras the IRS normally lets you exclude — mainly non-taxable Social Security and tax-free interest. It's the income number the Marketplace uses to decide your subsidy.

Details

Modified Adjusted Gross Income (MAGI) for ACA purposes is your IRS Adjusted Gross Income (AGI) plus tax-exempt interest, non-taxable Social Security benefits, and excluded foreign income.

Exceptions: Self-employed individuals can deduct business expenses to reduce net self-employment income. Health insurance premiums paid by self-employed individuals reduce MAGI. IRA deduction rules can also affect AGI and therefore MAGI.
Escalate If: The client has complex self-employment income, significant capital gains, rental losses, or business deductions that materially affect their MAGI estimate and subsidy eligibility.
5
Social Security

Does Social Security count as income?

Quick Answer

Yes — Social Security retirement and disability benefits count as income for ACA purposes. SSI (Supplemental Security Income) does not count.

Details

Yes, Social Security income generally counts toward MAGI for ACA subsidies. The taxable portion of Social Security always counts, and the non-taxable portion is added back into MAGI.

Exceptions: SSI does not count. Workers' compensation does not count. Veterans' disability compensation generally does not count as MAGI. Social Security income that pushes someone above 400% FPL eliminates subsidy eligibility entirely in 2026.
Escalate If: Social Security income places the client near a critical threshold (138% FPL for Medicaid, 400% FPL for subsidy cliff) where small variations significantly change coverage options.

Chapter 8: Medicaid CHIP

1
Medicaid

How does the Marketplace work with Medicaid?

Quick Answer

When you apply on the Marketplace, it automatically checks whether you qualify for Medicaid or CHIP. If you do, it sends your application to the state Medicaid office. Some family members may get Medicaid while others get Marketplace coverage.

Details

When you apply through the Marketplace, it automatically screens your household for Medicaid and CHIP eligibility and routes eligible members to those programs instead of — or alongside — Marketplace plans.

Exceptions: In non-expansion states (AL, FL, GA partial, KS, MS, SC, TN, TX, WI, WY), adult Medicaid eligibility thresholds are much lower — often requiring children or pregnancy. Some states have ongoing Medicaid eligibility redetermination backlogs that can affect transition timing.
Escalate If: The Marketplace has referred the client to Medicaid but state Medicaid has not processed the application, creating a coverage gap; or the client disagrees with the Medicaid determination and needs to appeal.
2
CHIP

How does the Marketplace work with CHIP?

Quick Answer

CHIP covers kids from families who make too much for Medicaid but need help with costs. The Marketplace screens for CHIP automatically. Parents can still get their own Marketplace plan while kids are on CHIP.

Details

The Marketplace screens children for CHIP eligibility. Children who qualify for CHIP are directed there rather than to Marketplace plans. Adults who apply can still get Marketplace coverage independently.

Exceptions: Some states have waiting periods (up to 90 days) before CHIP coverage begins. Medicaid-eligible children are covered under Medicaid, not CHIP. CHIP-eligible children cannot receive Marketplace premium tax credits for themselves.
Escalate If: The family is in a state with a CHIP waiting period and the child needs immediate coverage, or there is a question about whether the child is on Medicaid vs. CHIP and what services are covered under each program.
3
Medicaid

Can the Marketplace decide that I qualify for Medicaid?

Quick Answer

Yes — if the Marketplace thinks you qualify for Medicaid based on your income, it automatically sends your application to the state Medicaid office. You don't have to apply separately.

Details

Yes. When you apply through the Marketplace, it determines whether you appear eligible for Medicaid based on your income and household information, then sends your case to the state Medicaid agency for final enrollment.

Exceptions: Some states have separate Medicaid eligibility systems that do not accept automated Marketplace transfers well, causing delays. In non-expansion states, adults who don't fit Medicaid categories may be incorrectly screened and need manual review.
Escalate If: The Marketplace transferred the client to Medicaid but the state has not enrolled them or responded, leaving them without coverage; or the client wants to contest the Medicaid determination and choose a Marketplace plan instead.
4
CHIP

What if my child qualifies for CHIP but I do not?

Quick Answer

Yes, this is common. Your child can be on CHIP while you use a Marketplace plan. Each family member can be on a different program based on their own eligibility.

Details

Yes, your child can qualify for CHIP while you do not qualify for Medicaid and instead enroll in a Marketplace plan. This is a common 'split-benefit' household situation.

Exceptions: Children who are eligible for CHIP but the family prefers Marketplace coverage should understand that children on CHIP typically cannot also receive Marketplace PTC. Some states allow opting out of CHIP for Marketplace coverage but PTC would not apply to the child.
Escalate If: The family wants Marketplace coverage for their CHIP-eligible child (perhaps for network reasons) and needs guidance on whether CHIP can be declined and what happens to the child's subsidy eligibility.
5
Medicaid

Can some family members get Medicaid and others get Marketplace coverage?

Quick Answer

Absolutely yes. In the same family, one parent might be on Medicaid, the kids on CHIP, and the other parent on a Marketplace plan. That's completely normal and the Marketplace is designed to handle it.

Details

Yes, it is common for different family members to be covered by different programs — some on Medicaid, some on CHIP, and others on Marketplace plans — based on each person's individual eligibility.

Exceptions: Having a family member on Medicaid or CHIP reduces the household size used in some APTC calculations for the Marketplace portion. Agents should verify how the Marketplace calculation handles the split when completing applications.
Escalate If: There is confusion about which family member is on which program, or the Marketplace application did not correctly route some members to Medicaid/CHIP, resulting in incorrect plan enrollment or subsidy calculation.

Chapter 9: Employer Coverage

1
Plan Selection

Can I buy a Marketplace plan if my employer offers insurance?

Quick Answer

Yes, you can always buy a Marketplace plan. But to get a subsidy, your employer's plan must be either too expensive (over 9.96% of your income in 2026) or cover too little (less than 60% of costs).

Details

Yes, you can buy a Marketplace plan even if your employer offers coverage. However, you can only receive premium tax credits if the employer's plan fails the affordability or minimum value tests.

Exceptions: Dependents may still qualify for Marketplace subsidies even if the employee's self-only offer is affordable — the 'family glitch' fix finalized in 2023 extended affordability testing to family coverage. Retirees under 65 not covered by an employer plan can always use the Marketplace.
Escalate If: The client's employer plan is borderline on affordability (close to the 9.96% threshold), or the minimum value question requires reviewing the plan's Summary of Benefits and Coverage, or a complex ICHRA or QSEHRA offer is involved.
2
Subsidies

Can I get subsidies if my job offers coverage?

Quick Answer

You can get subsidies only if your employer's plan costs you more than 9.96% of your household income (for 2026), or if the plan is skimpy and covers less than 60% of costs. Otherwise, no subsidy is available.

Details

You can only get Marketplace subsidies if your employer's plan is either unaffordable (employee share exceeds 9.96% of income in 2026) or fails to provide minimum value (covers less than 60% of costs).

Exceptions: The 2023 'family glitch fix' allows dependents to qualify for subsidies if the family premium (not just self-only) is unaffordable. ICHRA and QSEHRA offers have separate affordability testing rules that affect subsidy eligibility.
Escalate If: The client's employee premium is close to the affordability threshold and precise income information is needed to determine eligibility, or the employer plan's minimum value status is unclear.
3
Employer Coverage

What does affordable employer coverage mean?

Quick Answer

For 2026, your employer's plan is 'affordable' if what you pay for just your own coverage is less than 9.96% of your income. There's also a simple dollar-amount test: if you pay $129.89/month or less for self-only, it's always considered affordable.

Details

Employer coverage is 'affordable' for 2026 if the employee's required contribution for self-only coverage does not exceed 9.96% of household income. The FPL safe harbor amount is $129.89/month.

Exceptions: The family coverage premium is tested separately (post-family glitch fix) to determine whether dependents qualify for Marketplace subsidies. Alaska and Hawaii have different FPL safe harbor amounts due to higher FPL figures.
Escalate If: An employee's required contribution is very close to the 9.96% threshold and a precise determination requires verifying the exact plan premium and household income figures.
4
Employer Coverage

What is minimum value for employer coverage?

Quick Answer

An employer plan meets 'minimum value' if it pays at least 60% of your average medical costs — similar to a Bronze plan. Most normal employer plans pass this test easily. Very skimpy plans may fail.

Details

Minimum value means the employer's health plan pays at least 60% of the total allowed costs of benefits provided under the plan — equivalent to a Bronze plan's 60% actuarial value threshold.

Exceptions: Plans that are essentially 'skinny' (covering only preventive care or outpatient-only benefits) may fail minimum value. Health reimbursement arrangements (HRAs) that stand alone without a major medical plan do not meet minimum value.
Escalate If: An employee believes their employer's plan fails minimum value but is not certain — they should request the plan's Summary of Benefits and Coverage and seek verification, potentially referring to a benefits advisor or HR department.
5
Subsidies

Can dependents get subsidies if the employee's offer is affordable only for self-only coverage?

Quick Answer

Yes — since 2023, the 'family glitch' has been fixed. If adding your family to your employer's plan costs more than 9.96% of your household income, your family can get Marketplace subsidies even if your own coverage is affordable.

Details

Yes — following the 2023 'family glitch fix,' dependents can qualify for Marketplace subsidies if the cost of family coverage (not just self-only coverage) is unaffordable, even if the employee's self-only offer passes the affordability test.

Exceptions: The employee with the 'affordable' self-only offer still cannot receive Marketplace subsidies for themselves. Only the dependents can receive Marketplace APTC when the family plan is unaffordable. The employee and dependents must be on separate applications in some systems.
Escalate If: The household is considering a split-coverage strategy (employee on employer plan, family on Marketplace) and the APTC calculation and enrollment logistics need careful coordination.

Chapter 10: Immigration Docs

1
Immigration

Can lawfully present immigrants enroll in Marketplace coverage?

Quick Answer

Many immigrants who are here legally can use the Marketplace — green card holders, refugees, asylum seekers, TPS holders, and many visa holders all qualify. DACA recipients cannot enroll as of August 25, 2025. Undocumented immigrants cannot enroll.

Details

Yes, many lawfully present immigrants can enroll in Marketplace health plans. Eligible categories include lawful permanent residents, refugees, asylees, TPS holders, visa holders, and others with valid lawful presence documentation.

Exceptions: DACA recipients lost Marketplace eligibility effective August 25, 2025. Undocumented immigrants are ineligible for Marketplace plans but may qualify for Emergency Medicaid and some state-funded programs. Non-immigrant visa holders' eligibility depends on their specific visa category.
Escalate If: The client's immigration status is unclear or they have a complex combination of categories (e.g., pending adjustment of status, mixed-status household) — refer to an immigration-trained navigator or legal aid organization.
2
Plan Selection

Do undocumented immigrants qualify for Marketplace plans?

Quick Answer

No — undocumented immigrants cannot buy Marketplace plans or get subsidies. Their U.S. citizen children can get coverage. Emergency Medicaid is available for genuine emergencies. Community health centers serve everyone regardless of status.

Details

No. Undocumented immigrants (those without lawful immigration status) cannot enroll in Marketplace health plans or receive premium tax credits. They also cannot enroll in Medicaid for non-emergency services.

Exceptions: Emergency Medicaid covers acute emergencies. CHIP Unborn Child programs in some states provide prenatal care. Some states use state-only funds to cover undocumented immigrants in limited programs (e.g., California's Medi-Cal for All).
Escalate If: The client appears to be undocumented but has a U.S. citizen child or a family member with lawful status who needs Marketplace coverage — the lawful-status members can enroll without revealing the undocumented member's status.
3
Mixedstatus Families

Can mixed-status families apply?

Quick Answer

Yes — in a mixed-status family, the members who are lawfully present or U.S. citizens can apply for Marketplace coverage. Undocumented members don't need to be included in the application. The Marketplace does not report information to immigration enforcement.

Details

Yes. Mixed-status families — where some members are lawfully present or U.S. citizens and others are undocumented — can apply for Marketplace coverage for the eligible members only.

Exceptions: The income of undocumented household members is still counted in the household MAGI for eligible members' subsidy calculations, which can affect the subsidy amount. However, undocumented members are excluded from the household count for FPL purposes in some calculations — this is a complex area.
Escalate If: The mixed-status family includes DACA recipients who are no longer Marketplace-eligible (as of August 25, 2025) and the family needs to understand their new coverage options.
4
Citizenship

Can U.S. citizen children get coverage if parents are undocumented?

Quick Answer

Yes — U.S. citizen children can get Marketplace coverage, Medicaid, or CHIP based on their own citizenship and your family's income. The parents' immigration status doesn't affect the child's eligibility.

Details

Yes. U.S. citizen children can enroll in Marketplace plans, Medicaid, or CHIP based on their own citizenship status and household income, regardless of their parents' immigration status.

Exceptions: If the child does not have a Social Security number yet (e.g., for very young children), there are processes to apply pending SSN issuance. Some states require the SSN before processing CHIP or Medicaid for a child, but the Marketplace has workarounds.
Escalate If: The undocumented parent is concerned about applying on behalf of their citizen child due to privacy concerns — reassure them that Marketplace data is not shared with immigration enforcement, but escalate if there are specific fears or unusual circumstances.
5
Immigration

What immigration documents may be requested?

Quick Answer

The Marketplace may ask to see your immigration paperwork to confirm you're lawfully present. A green card, work permit, refugee document, or valid visa with I-94 are commonly accepted. Have your documents ready when applying.

Details

The Marketplace may request immigration documents to verify lawful presence. Common documents include permanent resident cards (green cards), Employment Authorization Documents (EADs), refugee admission documents, asylee approval notices, TPS approval notices, and valid non-immigrant visas with I-94.

Exceptions: Some documents auto-extend even when the printed expiration date has passed (e.g., green cards extended by USCIS filing receipts for renewal). DACA recipients' EADs no longer confer Marketplace eligibility as of August 25, 2025.
Escalate If: The client's immigration documents are expired, lost, or contain errors that prevent electronic verification — refer to an immigration attorney or legal aid to address document issues before attempting Marketplace enrollment.

Chapter 11: Plan Levels

1
Silver Plans

What are Bronze, Silver, Gold, and Platinum plans?

Quick Answer

The metal level tells you how costs are split between you and your insurance company. Bronze means you pay more when you use care but less per month. Platinum means you pay less when you use care but more per month. Silver is the middle ground — and the only level where you can get extra cost savings if your income qualifies.

Details

Bronze, Silver, Gold, and Platinum are ACA 'metal levels' — they represent how costs are split between you and the plan. Bronze covers about 60% of average costs; Silver 70%; Gold 80%; Platinum 90%.

Exceptions: Catastrophic plans sit outside the four metal tiers and are available only to people under 30 or with a hardship/affordability exemption — they are not eligible for premium subsidies. CSR-enhanced silver plans technically have higher actuarial values (73%, 87%, or 94% AV) but are still sold as 'Silver' plans.
Escalate If: The client is making a plan selection decision and needs help comparing specific plan designs, networks, or drug formularies — use the plan comparison tool at HealthCare.gov or the specific carrier's Summary of Benefits and Coverage.
2
Metal Levels

How do metal levels affect out-of-pocket costs?

Quick Answer

Higher metal = higher monthly premium but lower bills when you go to the doctor. Lower metal = lower monthly premium but you pay more each time you use care. Everyone hits the same maximum out-of-pocket cap once costs add up.

Details

Higher metal levels (Gold, Platinum) mean lower out-of-pocket costs when you receive care — smaller deductibles, lower copays, and lower coinsurance. Lower metal levels (Bronze) mean higher out-of-pocket costs but lower monthly premiums.

Exceptions: Preventive services (A/B rated USPSTF recommendations) are covered at $0 cost-sharing regardless of metal level or whether the deductible is met. This is an ACA requirement that applies to all metal levels.
Escalate If: The client has a chronic condition, takes expensive medications, or anticipates significant healthcare use — they need a detailed plan comparison that weighs total annual cost (premium + expected out-of-pocket) rather than just the metal tier label.
3
Which Metal

Which metal level usually has the lowest premium?

Quick Answer

Bronze plans have the lowest monthly premiums — but you'll pay more when you actually use healthcare. If you're eligible for a subsidy, your net cost after the subsidy can make Silver or Gold plans equally affordable on a monthly basis.

Details

Bronze plans have the lowest monthly premiums of the four standard metal levels. Catastrophic plans have even lower premiums but are only available to people under 30 or with a specific exemption.

Exceptions: Catastrophic plans (available only under age 30 or with hardship/affordability exemption) may have lower premiums than Bronze plans but are not eligible for premium tax credits. CSR-enhanced Silver plans for very low income enrollees may cost less net than Bronze after subsidies.
Escalate If: The client is over 400% FPL and is shocked by the unsubsidized premium cost — explain the return of the subsidy cliff in 2026 and explore whether the client qualifies for employer coverage or other options.
4
Costs

Which metal level usually has the lowest deductible?

Quick Answer

Platinum plans almost always have the lowest deductibles — sometimes zero. Bronze plans have the highest deductibles, which means you pay the full cost for most services until you meet that high amount. Preventive care is always free regardless of deductible.

Details

Platinum plans typically have the lowest deductibles — often $0 or very low amounts — because they have the highest actuarial value (~90%). Gold plans also have low deductibles. Bronze plans generally have the highest deductibles.

Exceptions: Some Bronze High Deductible Health Plans (HDHPs) may be compatible with a Health Savings Account (HSA). HSA-eligible Bronze plans require meeting the deductible before most care is covered (except preventive), but the HSA allows pre-tax savings to cover those costs.
Escalate If: The client has high ongoing medical costs and is comparing plans based on deductible — they should run a total annual cost analysis (premium + expected out-of-pocket) to determine true value, which requires plan-specific data from the carrier or comparison tool.
5
Metal Levels

Are benefits the same across metal levels?

Quick Answer

Yes — all Marketplace plans cover the same basic set of health services no matter which metal level. The difference is how much you pay for those services, not whether they're covered at all.

Details

Yes — all ACA Marketplace plans at every metal level must cover the same 10 Essential Health Benefits. What differs between metal levels is how much the plan pays vs. how much you pay, not what services are covered.

Exceptions: Catastrophic plans also cover the 10 EHBs but require meeting the full deductible (which equals the out-of-pocket maximum) before most benefits kick in — except for three primary care visits and preventive services per year. Dental EHBs for adults are often offered as a separate standalone dental plan, not embedded in the medical plan.
Escalate If: The client is comparing plans and believes a lower metal plan does not cover a specific service — verify using the Summary of Benefits and Coverage (SBC) for both plans, as specific services may have different cost-sharing structures even if both plans cover them.

Chapter 12: Networks Providers

1
Networks

How do provider networks work in ACA plans?

Quick Answer

Your plan's network is the list of doctors and hospitals that your insurance company has an agreement with. Use providers on that list to pay the lowest amounts. If you go outside the list, you'll pay a lot more — or possibly the full cost.

Details

ACA plan provider networks are the set of doctors, hospitals, and other providers that have contracted with the insurer to provide care at negotiated rates. Using in-network providers results in lower cost-sharing; going out-of-network usually costs significantly more or is not covered at all.

Exceptions: Emergency care must always be treated as in-network for cost-sharing purposes under the ACA, regardless of the facility's network status. Mental health network adequacy is regulated — plans cannot have substantially smaller mental health networks than their medical/surgical networks (mental health parity).
Escalate If: The consumer has an ongoing specialist relationship, is managing a serious illness with a specific treatment team, or is planning a surgery at a specific hospital — they must verify network participation directly with the carrier before enrolling, not just through the online directory.
2
Difference Between

What is the difference between HMO, PPO, EPO, and POS plans?

Quick Answer

HMO: cheapest, but you need your primary doctor to refer you everywhere, and no out-of-state coverage. PPO: most flexible, you can see any doctor anywhere, but it costs more. EPO: like PPO for ease but no coverage outside the network. POS: a blend of HMO and PPO.

Details

HMO requires using a primary care physician and getting referrals to see specialists; PPO allows self-referrals with both in- and out-of-network coverage; EPO requires in-network use only (no out-of-network coverage except emergencies) with no referrals; POS combines HMO's PCP gatekeeper with PPO's out-of-network option.

Exceptions: Regardless of plan type, emergency services must be covered at in-network cost-sharing rates by all plan types. Mental health parity applies to all plan types. Transitional care (continuing care for ongoing treatment with a non-network provider after plan change) is required for a reasonable transition period.
Escalate If: A consumer with out-of-state care needs (travel nurses, border-area residents, students at out-of-state schools) must verify coverage carefully — HMO and EPO plans may leave them without coverage when away from home except for emergencies.
3
Plan Selection

Can I keep my current doctor with a Marketplace plan?

Quick Answer

Don't assume your doctor is covered just because they work with that insurance company. Each plan has its own network — always look up your doctor in the specific plan you're considering before enrolling, and call the doctor's office to double-check.

Details

Not necessarily. You must check whether your specific doctor participates in the specific plan you're considering — not just whether they accept the insurer's other plans or the same metal level from that carrier. Always verify directly with the plan's provider directory or call the carrier.

Exceptions: Emergency providers at an in-network hospital cannot balance-bill you for emergency care under the No Surprises Act, even if the emergency physician is out-of-network. Transitional care provisions may allow you to continue seeing an out-of-network provider for ongoing treatment for a limited period when you switch plans.
Escalate If: The consumer's care depends on maintaining access to a specific provider (oncologist, transplant center, psychiatrist) — this requires more than a directory check. Get written confirmation from the carrier that the specific provider is in-network for the specific plan for the current plan year.
4
Networks

How do I check whether a provider is in network?

Quick Answer

Check the insurance company's website or the plan details on HealthCare.gov to find the doctor search tool for that specific plan. Then call the doctor's office and double-check. Don't skip the call — online directories can be out of date.

Details

To verify whether a provider is in-network, use the plan's official online provider directory (accessed through the carrier's website or HealthCare.gov plan details), and then confirm by calling the doctor's office or the insurance carrier directly.

Exceptions: Free-standing emergency rooms and physician groups at hospitals may not be listed in directory searches by facility name — you must search for the specific physician. Air ambulance providers are often not in-network for any standard Marketplace plan; No Surprises Act protections limit cost for air ambulance services.
Escalate If: The consumer is making a plan decision specifically based on keeping access to a current oncologist, transplant center, or specialized treatment program — the agent should obtain written carrier confirmation and document it, not rely solely on an online directory.
5
Networks

What happens if I go out of network?

Quick Answer

If you see a doctor or go to a hospital that's not in your plan's network, you'll pay much more — and for some plan types (HMO, EPO), the insurance won't cover it at all unless it's a true emergency. Emergency care is always covered at in-network rates regardless of where you go.

Details

Going out-of-network means you'll pay significantly more — or possibly 100% of the cost. On HMO/EPO plans, non-emergency out-of-network care is usually not covered at all. On PPO/POS plans, out-of-network care is covered but with higher deductibles and coinsurance.

Exceptions: Emergency care is always covered at in-network rates under ACA, even at a fully out-of-network facility. Air ambulance is subject to No Surprises Act protections — cost-sharing limited to in-network level. Transitional care: if your doctor leaves the network mid-treatment, you typically get a grace period to continue care at in-network rates.
Escalate If: The consumer received an out-of-network bill for services they believed were in-network — this may be a No Surprises Act violation if it involves emergency care or ancillary services at an in-network facility. Help them file a complaint with their insurer and/or state insurance department.

Chapter 13: Drug Coverage

1
Prescription Drugs

Do ACA plans cover prescription drugs?

Quick Answer

Every ACA plan must cover prescription drugs, but each plan has its own list of covered drugs (called a formulary), so the same medication could cost very different amounts depending on which plan you choose.

Details

Yes, prescription drugs are an Essential Health Benefit (EHB) that all ACA Marketplace plans must cover, though each plan's formulary — its list of covered drugs — differs by insurer and metal level.

Exceptions: Grandfathered health plans are not required to cover prescription drugs as an EHB. Plans sold outside the Marketplace (short-term, indemnity) are not required to cover EHBs at all.
Escalate If: A client needs to verify that a specific medication is covered at a particular tier before enrolling, or is disputing a denial of a covered drug.
2
Formulary

What is a formulary?

Quick Answer

A formulary is a list of drugs your insurance plan covers. Drugs are grouped into tiers — the lower the tier, the less you pay. If your drug is not on the list, you may have to pay full price or request an exception.

Details

A formulary is a plan's official list of covered prescription drugs, organized into tiers that determine how much you pay for each drug.

Exceptions: Drugs approved after the plan year begins may not be added to the formulary mid-year unless required by state law or a formulary exception process. Compounded medications are typically not on formularies.
Escalate If: A client's critical medication is not on any formulary in their area, or they need help filing a formulary exception or appeal.
3
Check Whether

How can I check whether my medication is covered?

Quick Answer

Go to HealthCare.gov or the insurance company's website and use their drug search tool. Type in your medication name to see if it's covered, what tier it's on, and what you'll pay.

Details

Use the plan's drug formulary search tool on HealthCare.gov or the insurer's website; enter your medication name and confirm its tier, cost-sharing, and any utilization management requirements before enrolling.

Exceptions: State-based Marketplace websites (California, New York, etc.) have their own plan comparison tools. Some plans use a separate PBM portal for formulary lookups.
Escalate If: A client cannot find their medication in any plan's formulary or needs a formulary exception request submitted to the insurer.
4
Prescription Drugs

Do all plans cover the same drugs?

Quick Answer

No — every plan must cover some prescription drugs, but each plan's list (formulary) is different. A drug covered cheaply on one plan could be very expensive or not covered at all on another.

Details

No. While all ACA plans must cover prescription drugs as an EHB, each plan has its own formulary, so the same drug may be covered differently — on a different tier or not covered at all — depending on the plan.

Exceptions: Emergency supply rules may allow short-term fills of a non-formulary drug. Biosimilar substitution rules vary by state and plan.
Escalate If: A client takes a specialty or high-cost drug and needs a detailed side-by-side formulary comparison across available plans before making an enrollment decision.
5
Prescription Drugs

What is prior authorization for prescriptions?

Quick Answer

Prior authorization means your doctor must get the insurance company's approval before they'll pay for a drug. Without that approval, you may have to pay full price.

Details

Prior authorization (PA) is a requirement that your doctor obtain approval from the insurance plan before the plan will cover a specific drug or service.

Exceptions: Emergency fills at a pharmacy (typically 72-hour emergency supply) may be allowed without prior authorization in many states. Preventive medications with an A or B USPSTF rating cannot require prior authorization.
Escalate If: A PA request has been denied and the client needs help filing an internal appeal or requesting an independent external review.

Chapter 14: EHB Preventive

1
Essential Health Benefits

What are essential health benefits?

Quick Answer

EHBs are 10 categories of care — like hospital stays, prescriptions, and mental health treatment — that every ACA plan must cover. Every plan must have all 10, though the specific services within each category can vary.

Details

Essential Health Benefits (EHBs) are 10 categories of services that all ACA Marketplace and most individual and small-group plans must cover: ambulatory care, emergency, hospitalization, maternity/newborn, mental health/SUD, prescription drugs, rehab/habilitative, lab, preventive/wellness, and pediatric (including oral and vision).

Exceptions: Grandfathered health plans are not required to cover all EHBs. Large employer self-funded plans are not required to cover EHBs, though many do. Catastrophic plans must cover 3 primary care visits per year before the deductible and all EHBs after the deductible.
Escalate If: A client is disputing an insurer's denial of a service they believe is an EHB, or needs clarification on whether a specific treatment falls within an EHB category.
2
Preventive Care

Do ACA plans cover preventive services?

Quick Answer

Yes. ACA plans must cover many preventive services — like annual physicals, mammograms, vaccines, and colorectal cancer screening — for free, with no copay and no deductible, as long as you use an in-network provider.

Details

Yes. ACA plans must cover preventive services rated 'A' or 'B' by the USPSTF, ACIP-recommended vaccines, and women's preventive services with no cost-sharing — no copay, no deductible.

Exceptions: Grandfathered plans are exempt from the preventive services mandate. If a preventive visit also involves diagnosing or treating a problem, cost-sharing may apply to the non-preventive portion of the visit.
Escalate If: A client received a bill for a preventive service they believe should have been covered at no cost, and needs help disputing the claim or filing an appeal.
3
Preventive Care

What preventive care is often covered without cost sharing?

Quick Answer

Free preventive care includes annual physicals, vaccines, cancer screenings (like colonoscopies and mammograms), cholesterol checks, depression screening, and birth control for women — all at no charge when done in-network.

Details

Covered preventive services with no cost-sharing include blood pressure and cholesterol screening, colorectal cancer screening (colonoscopy, stool tests), mammograms, Pap smears, routine vaccines, depression screening, obesity counseling, tobacco cessation, and contraception for women.

Exceptions: Routine preventive services become diagnostic (and subject to cost-sharing) if performed to diagnose a symptom rather than as a routine screen. For example, a colonoscopy ordered because of rectal bleeding is diagnostic, not preventive.
Escalate If: A client was charged for a service they believe should have been preventive and cost-free, or was billed for a vaccine at an in-network pharmacy.
4
Aca Plans

Do ACA plans cover maternity care?

Quick Answer

Yes. All ACA plans must cover maternity care, including prenatal visits, labor and delivery, and care for the newborn. You'll still have copays and deductibles, but the coverage must be there.

Details

Yes. Maternity and newborn care is one of the 10 EHB categories, so all ACA Marketplace plans must cover prenatal visits, labor and delivery, and newborn care.

Exceptions: Grandfathered individual plans purchased before March 23, 2010 may not include maternity coverage. Some short-term plans also exclude maternity.
Escalate If: A client's maternity-related claim is denied, a specific birthing facility or OB-GYN is out-of-network, or coverage questions arise about a high-risk pregnancy requiring specialized care.
5
Aca Plans

Do ACA plans cover mental health services?

Quick Answer

Yes. All ACA plans must cover mental health services and addiction treatment. Under federal parity law, your plan can't make mental health care harder to access than physical health care.

Details

Yes. Mental health and substance use disorder (MH/SUD) services are one of the 10 EHBs, and the Mental Health Parity and Addiction Equity Act (MHPAEA) requires plans to cover them at parity with medical/surgical benefits.

Exceptions: Prior authorization may still be required for inpatient psychiatric stays or residential treatment. Coverage levels depend on in-network vs. out-of-network status and whether the plan uses managed behavioral health organizations.
Escalate If: A client's mental health or SUD treatment claim is denied for reasons that may violate parity, or an insurer is imposing more restrictive prior authorization for therapy than for comparable medical services.

Chapter 15: Costs OOP

1
Costs Look

What costs should I look at besides the monthly premium?

Quick Answer

Don't just look at the monthly premium. Also check the deductible (what you pay before insurance kicks in), the copays for doctor visits and drugs, and the out-of-pocket maximum (the most you'd ever pay in a year — $10,600 for one person in 2026).

Details

Beyond the monthly premium, evaluate the deductible, copays and coinsurance for specific services, the out-of-pocket maximum, and whether your doctors, hospitals, and drugs are in-network — these often matter more than the premium for people who use healthcare regularly.

Exceptions: Cost-sharing reductions (CSRs) on Silver plans for enrollees at 100–250% FPL can dramatically lower the deductible and OOP maximum compared to standard Silver plan levels.
Escalate If: A client needs a full total cost analysis comparing two or more plans based on their specific expected healthcare utilization, income, and subsidy eligibility.
2
Costs

What is a deductible?

Quick Answer

The deductible is the amount you pay yourself for medical care before your insurance starts paying. If your deductible is $2,000, you pay the first $2,000 of medical bills each year. After that, your insurance kicks in.

Details

The deductible is the dollar amount you must pay for covered services each plan year before your insurance begins paying its share. For 2026, individual deductibles on ACA Marketplace plans can range from $0 to several thousand dollars depending on the metal level and plan design.

Exceptions: Preventive services with USPSTF A/B ratings are covered at $0 before the deductible is met. Some plans also exempt Tier 1 generic drugs from the deductible. Catastrophic plans have deductibles equal to the OOP maximum except for 3 primary care visits.
Escalate If: A client does not understand why they are being charged full price for a medical service that they believe should be covered — they may not have met their deductible yet.
3
Costs

What is a copay?

Quick Answer

A copay is a fixed fee you pay when you use a service — like $35 for a doctor visit or $15 for a generic medication. You pay the same amount regardless of the total bill.

Details

A copay is a fixed dollar amount you pay for a specific covered service at the time of service — for example, $35 for a primary care visit or $20 for a generic prescription — regardless of the total cost of the service.

Exceptions: Copays for preventive services covered under the ACA's preventive mandate are $0. Copays may be suspended once the OOP maximum is reached. Some plans have no copays and use coinsurance only.
Escalate If: A client is being charged a copay for a service they believe should be cost-free (preventive) or has reached their OOP maximum and is still being charged copays.
4
Costs

What is coinsurance?

Quick Answer

Coinsurance is your share of a medical bill, expressed as a percentage. If your coinsurance is 20%, you pay 20% of the insurance company's negotiated rate for the service — after you've already met your deductible.

Details

Coinsurance is your percentage share of the cost of a covered service after you have met your deductible. For example, 20% coinsurance means you pay 20% of the allowed amount and the plan pays 80%.

Exceptions: Coinsurance does not apply once the OOP maximum is reached. Preventive services covered under the ACA are 0% coinsurance. Some plans use copays for all services and have no coinsurance.
Escalate If: A client received a coinsurance bill for a service after reaching their OOP maximum, or received an unexpectedly high coinsurance amount based on the billed charge rather than the contracted rate.
5
Costs

What is the out-of-pocket maximum?

Quick Answer

The out-of-pocket maximum is your financial safety net — the most you'll ever pay for covered in-network care in a year. In 2026, that cap is $10,600 for one person and $21,200 for a family. After that, your insurance pays 100%.

Details

The out-of-pocket maximum is the most you will pay for covered, in-network essential health benefits in a plan year. For 2026, the federal OOP maximums are $10,600 for individual coverage and $21,200 for family coverage — no ACA plan can exceed these amounts.

Exceptions: Out-of-network costs, balance bills, and non-EHB services do not count toward the OOP maximum. Plans with embedded individual OOP maximums within a family plan may have lower per-person caps.
Escalate If: A client has met their OOP maximum but the insurer or a provider is still charging cost-sharing for covered in-network EHB services — this is impermissible and should be escalated immediately.

Chapter 16: Special Enrollment

1
Special Enrollment

What life events can trigger a Special Enrollment Period?

Quick Answer

You can sign up for ACA coverage outside of Open Enrollment if something big happens in your life — like losing job-based insurance, getting married, having a baby, or moving to a new area. You usually have 60 days from that event to enroll.

Details

Qualifying life events for an SEP include loss of minimum essential coverage, marriage, birth/adoption/foster placement, permanent move to a new coverage area, gaining lawful immigration status, loss of Medicaid/CHIP, and certain other events. SEPs generally last 60 days from the qualifying event.

Exceptions: Loss of Medicaid/CHIP gives a 90-day SEP in most states. Some state-based Marketplaces have additional SEP triggers (e.g., pregnancy as a qualifying event in some states). Voluntary loss of coverage (quitting a job to lose insurance) is generally not a qualifying event.
Escalate If: A client believes they qualify for an SEP but the Marketplace is not recognizing the event, or a client's SEP window is about to expire and they have not yet enrolled.
2
Losing Health

Does losing health coverage trigger an SEP?

Quick Answer

Yes. If you lose your health insurance — like when you leave a job, get laid off, or turn 26 and come off your parents' plan — you have 60 days to sign up for a new Marketplace plan. Act quickly so there's no gap in coverage.

Details

Yes. Losing minimum essential coverage (MEC) involuntarily — such as when job-based insurance ends, COBRA expires, or a plan is discontinued — triggers a 60-day SEP to enroll in Marketplace coverage.

Exceptions: Voluntarily dropping employer coverage without a qualifying reason does not create a loss-of-coverage SEP. Losing coverage due to non-payment of premiums is also generally not treated as an involuntary loss.
Escalate If: A client lost coverage more than 60 days ago and may have missed the SEP window, or their proof of coverage loss is being rejected by the Marketplace verification system.
3
Moving Trigger

Does moving trigger an SEP?

Quick Answer

Yes. If you move to a new city, county, or state, you have 60 days to pick a new ACA plan in your new area. You'll need to prove the new address with a document like a utility bill or lease.

Details

Yes. A permanent move to a new county, ZIP code, or state that makes new Marketplace plans available triggers a 60-day SEP, even if you already have coverage — provided you had coverage before the move (or recently gained it).

Exceptions: Seasonal or temporary moves do not qualify. Moving to a new ZIP code within the same county may not qualify if the plan service area is the same. Proof of prior MEC is typically required.
Escalate If: A client moved more than 60 days ago and did not realize they had an SEP, or their proof of move is being rejected by the Marketplace.
4
Marriage Trigger

Does marriage trigger an SEP?

Quick Answer

Yes. Getting married is a qualifying event that gives you 60 days to change or get new health coverage. You'll need to show your marriage certificate and may need to update your income information since your household will now be combined.

Details

Yes. Getting married triggers a 60-day SEP. Both spouses can enroll in or change Marketplace plans, and the new household size and income are used to calculate subsidy eligibility.

Exceptions: Marriage in some states (common-law or domestic partnerships) may or may not qualify as a marriage SEP depending on state law and how the Marketplace defines 'marriage.' Confirm with the Marketplace for specific legal arrangements.
Escalate If: A client recently married and is unsure how to combine household income in the Marketplace application, or their marriage SEP request is being denied due to documentation issues.
5
Divorce Trigger

Does divorce trigger an SEP?

Quick Answer

Divorce qualifies for an SEP mainly if you lose your health coverage as a result — like if you were on your ex-spouse's insurance. If the divorce didn't change your coverage, you may not automatically get an SEP on the federal Marketplace, but state Marketplaces may differ.

Details

Yes, but only if the divorce results in loss of health coverage — divorce alone (without a coverage loss) may not trigger an SEP on the federal Marketplace, though some state-based Marketplaces recognize divorce as a standalone qualifying event.

Exceptions: Some state-based Marketplaces (e.g., Covered California, NY State of Health) recognize divorce/legal separation as a standalone qualifying event regardless of coverage loss.
Escalate If: A recently divorced client lost coverage and is unsure whether they qualify for an SEP, or their SEP request related to divorce is being denied by the Marketplace.

Chapter 17: 1095A 8962

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1095-A

What is Form 1095-A?

Quick Answer

Form 1095-A is a tax form from the health insurance Marketplace. It shows how much subsidy was paid on your behalf each month. You need this form to complete your federal taxes if you got a subsidy.

Details

Form 1095-A is the Health Insurance Marketplace Statement sent by the Marketplace to enrollees who had Marketplace coverage. It shows the months covered, the premium for the second-lowest-cost Silver plan (SLCSP), and the amount of advance premium tax credits (APTC) paid on your behalf.

Exceptions: Medicaid, Medicare, CHIP, and employer-plan enrollees do not receive a 1095-A (they receive 1095-B or 1095-C instead). People who were enrolled in Marketplace coverage but received no APTC still receive a 1095-A but may not need to file Form 8962 unless they want to claim the credit.
Escalate If: A client reports that their 1095-A contains incorrect premium amounts, wrong coverage months, or an incorrect SLCSP figure, as this will cause errors in Form 8962 and may require a corrected 1095-A from the Marketplace before filing.
2
1095-A

Who receives Form 1095-A?

Quick Answer

Anyone who bought health insurance through the Marketplace — HealthCare.gov or a state Marketplace — gets a 1095-A, whether or not they got a subsidy. Multiple forms are sent if you had more than one plan during the year.

Details

Every person or household that had health coverage through a Marketplace (HealthCare.gov or a state-based Marketplace) during the year receives a Form 1095-A, regardless of whether they received advance premium tax credits.

Exceptions: People enrolled in Medicaid, Medicare, CHIP, or employer plans do not receive a 1095-A. COBRA continuation coverage is not Marketplace coverage and also does not generate a 1095-A.
Escalate If: A client has not received their 1095-A by mid-February and needs to retrieve it or request a reissue from the Marketplace, or believes their 1095-A was sent to the wrong address.
3
Form 8962

What is Form 8962?

Quick Answer

Form 8962 is the IRS form you fill out at tax time to settle up your health insurance subsidy. It compares what the government already paid toward your premiums with what you were actually entitled to based on your real income.

Details

Form 8962 (Premium Tax Credit) is the IRS form used to calculate the actual premium tax credit you are entitled to based on your final household income and family size, and to reconcile it against any APTC paid in advance during the year.

Exceptions: Taxpayers who are claimed as a dependent on another person's return generally cannot claim the PTC. Married couples who file separately generally cannot claim the PTC (with a narrow exception for victims of domestic abuse or abandonment).
Escalate If: A client owes a large reconciliation amount on Form 8962 that creates a financial hardship, has a complex household situation (divorce, shared policy allocation), or needs a corrected 1095-A before the form can be completed.
4
Subsidies

Why do Marketplace subsidies have to be reconciled at tax time?

Quick Answer

The government pays your health insurance subsidy each month based on your estimated income. At tax time, you compare that estimate to your real income. If you earned more than expected, you pay some back. If you earned less, you get a refund.

Details

Marketplace subsidies are paid as advance premium tax credits (APTC) based on estimated income. At tax time, your actual income is compared to your estimate, and Form 8962 is used to settle the difference — paying back any excess or claiming any additional credit owed.

Exceptions: Taxpayers with income below 100% FPL are not eligible for the PTC (except lawfully present immigrants below 100% FPL who are ineligible for Medicaid). Above 400% FPL in 2026 (since enhanced credits expired), no PTC is available at all.
Escalate If: A client is facing a large unexpected repayment on Form 8962 and needs help understanding if the 1095-A figures are correct, or if they can reduce the repayment obligation through an amended return or repayment cap.
5
Subsidies

What happens if I got too much subsidy in advance?

Quick Answer

If you got more subsidy than you were entitled to based on your real income, you have to pay some back at tax time. There are limits on how much you have to repay if your income is moderate, but if your income was very high, you could owe the full amount back.

Details

If you received more APTC than your actual income entitles you to, you must repay the excess as additional tax on Form 8962. The repayment is capped for households with income between 100%–400% FPL; above 400% FPL, all excess APTC must be repaid.

Exceptions: In some years, Congress has waived or limited APTC repayment (as it did for tax year 2020). As of 2026, no such waiver is in effect. Certain victims of domestic abuse or abandonment filing separately may have different repayment calculations.
Escalate If: A client is facing a significant APTC repayment obligation that they believe is incorrect, or the repayment amount would create a serious financial hardship — they should consult a tax professional or IRS Volunteer Income Tax Assistance (VITA) program.

Chapter 18: Life Changes

1
Life Changes

What life changes should I report to the Marketplace?

Quick Answer

Tell the Marketplace whenever your family size, income, or health coverage changes — even mid-year — so your financial help stays accurate and you don't owe money at tax time.

Details

You should report any change to household size, income, or coverage status to the Marketplace as soon as possible, since these changes can affect your premium tax credit, cost-sharing reductions, and plan eligibility.

Exceptions: State-based Marketplaces (SBEs) such as Covered California, NY State of Health, or Get Covered Illinois may have their own portals and reporting procedures; consumers in those states must report changes to their SBE, not HealthCare.gov.
Escalate If: The consumer's income change could push them out of subsidy eligibility entirely (above 400% FPL), shift them to Medicaid, or create a complex household-composition situation requiring a manual eligibility review.
2
Income Changes

Why should I report income changes quickly?

Quick Answer

If your income goes up and you don't report it, you could face a surprise tax bill. If it drops, you may be paying too much for your plan. Updating your income mid-year fixes both problems.

Details

Reporting income changes quickly keeps your advance premium tax credit (APTC) accurate — if your income rises and you delay reporting, you may have to repay excess APTC when you file taxes; if it drops, you could be getting less help than you're entitled to.

Exceptions: Repayment of excess APTC is capped for lower-income households; for 2026, caps range from approximately $350 to $1,500 (single) or $700 to $3,000 (family) depending on income relative to FPL. Above 400% FPL, there is no cap — full repayment is required.
Escalate If: The income change causes the consumer to cross the 400% FPL threshold in either direction, involves a complex tax household (e.g., divorced parents claiming same dependents), or may trigger a mid-year transition to Medicaid or CHIP.
3
Report New

Should I report a new job to the Marketplace?

Quick Answer

Tell the Marketplace about your new job — especially if your employer offers health insurance — because it may reduce or eliminate your subsidy, or you may need to switch plans.

Details

Yes — starting a new job must be reported if it changes your household income or provides access to employer-sponsored insurance, since both affect your subsidy eligibility and coverage options.

Exceptions: Part-time jobs that do not come with an employer health offer do not affect subsidy eligibility on their own, though any income increase must still be reported. Self-employment income changes follow different reporting rules.
Escalate If: The consumer is unsure whether the employer offer is affordable, whether it provides minimum value, or whether COBRA from a prior job overlaps with the new employer's waiting period.
4
Report Losing

Should I report losing a job to the Marketplace?

Quick Answer

If you lose health insurance from a job, you have 60 days to sign up for a Marketplace plan — and with lower income, you may now qualify for subsidies or even Medicaid.

Details

Yes — losing job-based health coverage is one of the most common qualifying life events and triggers a 60-day Special Enrollment Period (SEP), during which you can enroll in or change a Marketplace plan.

Exceptions: Voluntary termination of employer coverage (e.g., declining COBRA) does not create an SEP on the federal Marketplace. However, COBRA exhaustion (running out of COBRA coverage) does trigger an SEP.
Escalate If: The consumer has COBRA rights and is weighing COBRA vs. Marketplace enrollment, or their income after job loss is below 100% FPL in a non-Medicaid-expansion state (coverage gap risk).
5
Report Marriage

Should I report marriage or divorce?

Quick Answer

Getting married or divorced changes who is in your household, which can change what coverage you qualify for. Both events let you update or switch plans within 60 days.

Details

Yes — both marriage and divorce must be reported because they change household size, income, and coverage eligibility, and both can trigger a 60-day Special Enrollment Period.

Exceptions: Divorce that does not cause loss of coverage (e.g., you were on your own plan already) may not trigger a Marketplace SEP, though income and household updates are still required. Legal separation rules vary by state.
Escalate If: Divorce involves complex shared-custody dependent situations, one spouse is in Medicaid and the other is in a Marketplace plan, or there is a dispute about which parent claims dependents for tax and subsidy purposes.

Chapter 19: Appeals Complaints

1
Appeals

Can I appeal a Marketplace eligibility decision?

Quick Answer

Yes, you can appeal if the Marketplace denies you coverage, subsidies, or other help. You have 90 days from the notice date to file, and you can do it online, by mail, or by fax.

Details

Yes — you can appeal most Marketplace eligibility decisions, including denials of enrollment, subsidy amounts, cost-sharing reductions, and Special Enrollment Periods. You generally have 90 days from the date on your eligibility notice to file.

Exceptions: State-based Marketplaces have their own appeal processes, which may have different deadlines, procedures, and addresses than the federal Marketplace. Medicaid appeal rights are separate from Marketplace appeal rights and go through the state Medicaid agency.
Escalate If: The appeal deadline is approaching within days, the consumer is currently without coverage and in need of care, or the appeal involves a complex eligibility question about immigration status or a data-matching error that requires legal or regulatory expertise.
2
Subsidies

Can I appeal a subsidy decision?

Quick Answer

If you think the Marketplace got your subsidy wrong — either too low or denied entirely — you can appeal with proof of your actual income. You have 90 days from the notice to do it.

Details

Yes — you can appeal a Marketplace decision about your subsidy (premium tax credit or cost-sharing reduction) amount within 90 days of the eligibility notice, providing documentation to support your income or household claim.

Exceptions: If the subsidy denial is due to a tax-filing failure (the 'APTC reconciliation suspension' issue), submitting proof of having filed Form 8962 can resolve the issue before or during an appeal. CSR disputes may require a plan-level enrollment correction in addition to the appeal.
Escalate If: The income discrepancy is large and involves self-employment income, retirement income, or other non-standard income types that require careful documentation; or the denial of APTC is causing the consumer to face an unaffordable premium mid-year.
3
Special Enrollment

Can I appeal a denial of a Special Enrollment Period?

Quick Answer

Yes — if the Marketplace denies your request to sign up outside the regular enrollment period, you can appeal. Gather any proof of your life event and submit it within 90 days.

Details

Yes — a denial of a Special Enrollment Period can be appealed within 90 days of the denial notice, and you should include documentation proving the qualifying life event occurred within the required timeframe.

Exceptions: Some SEP denials occur because the consumer provided incorrect event dates, submitted unclear documentation, or the event type does not qualify under federal rules. Correcting and resubmitting documents through the normal process (rather than a formal appeal) is sometimes faster if the SEP window has not fully expired.
Escalate If: The consumer has an urgent medical need and the SEP denial has left them without coverage, the documentation submitted was clearly sufficient and the denial appears to be a Marketplace processing error, or the qualifying event involves immigration status documentation.
4
Appeals

How do Marketplace appeals usually work?

Quick Answer

You file the appeal with documents showing why you think the decision was wrong, the Marketplace reviews everything, and sends you a written answer. You can usually keep your coverage going while you wait.

Details

Marketplace eligibility appeals are reviewed by the Marketplace Appeals Center: you submit your appeal with supporting documents, the center reviews the evidence against your eligibility notice, and issues a written decision — typically within 90 days.

Exceptions: State Medicaid appeals go through the state Medicaid agency's fair hearing process, not the Marketplace Appeals Center. Plan-level appeals (claim denials, prior authorization) go through the insurer, not the Marketplace.
Escalate If: The consumer is unable to submit the appeal due to language barriers, disabilities, or lack of internet access and needs in-person or phone assistance. Authorized representative designation paperwork must also be completed if someone other than the consumer is filing on their behalf.
5
Appeals

Are there deadlines to file an appeal?

Quick Answer

For Marketplace eligibility decisions, you have 90 days from the notice date to appeal. For insurance claim denials, you typically have 180 days to ask the insurer to reconsider.

Details

Yes — the standard deadline to file a Marketplace eligibility appeal is 90 days from the date printed on the Marketplace Eligibility Notice. For plan-level (insurance company) internal appeals, you generally have 180 days from the denial notice.

Exceptions: If you miss the 90-day deadline, the Marketplace may still accept a late appeal if you can demonstrate good cause for the delay (such as a serious illness, hospitalization, or a natural disaster). State-based Marketplaces may have different deadlines.
Escalate If: The deadline is within 5 business days and the consumer has not yet filed, or there is a question of whether good cause exists to file a late appeal.

Chapter 20: State Marketplaces

1
State Variation

Do ACA rules work the same in every state?

Quick Answer

The basic ACA protections are the same everywhere, but big things like when enrollment ends, whether Medicaid is available, and extra financial help vary a lot from state to state.

Details

No — while the core ACA federal requirements apply in every state, there are significant state-level differences in Marketplace type, open enrollment deadlines, Medicaid expansion status, additional subsidies, and state-specific rules.

Exceptions: Federal minimum protections apply everywhere, including guaranteed issue, no lifetime limits, dependent coverage to age 26, and free preventive care. These cannot be waived by states. States can add protections but not eliminate federal minimums.
Escalate If: A consumer is moving between states with very different Medicaid expansion statuses or subsidy programs, requiring careful coordination to avoid coverage gaps or incorrect subsidy calculations.
2
State Variation

What is the difference between HealthCare.gov and a state Marketplace?

Quick Answer

HealthCare.gov is a federally run website most states use to sign up for health insurance. But 21 states have their own websites and their own rules — if you live in one of those, you use their site instead.

Details

HealthCare.gov is the federally run Marketplace used by most states; state Marketplaces (SBEs) are operated by individual states with their own websites, enrollment systems, and sometimes additional subsidies or broader rules.

Exceptions: SBE states cannot offer plans with fewer protections than federal ACA minimums, but they can offer more. Consumers in SBE states who use HealthCare.gov by mistake will be redirected to their state's exchange.
Escalate If: A consumer is unsure which exchange to use, is getting conflicting information from HealthCare.gov and a state SBE, or is a recent mover from one state to another where the exchange type differs.
3
State Variation

Do plan choices vary by county and state?

Quick Answer

The health plans available to you depend on where you live, right down to your county. People in different counties of the same state may have very different plan options and prices.

Details

Yes — plan availability varies significantly by county and state, since health insurers choose which counties to serve and plans are sold within specific geographic service areas defined at the county level.

Exceptions: Catastrophic plans are available nationally to people under 30 or with a hardship exemption, regardless of county-level insurer participation. CHIP and Medicaid are available statewide regardless of Marketplace insurer participation.
Escalate If: A consumer is moving to a county with very limited plan options (potentially just one insurer) and needs to verify whether their current doctors, medications, and specialists will be covered under the available plans before making enrollment decisions.
4
Medicaid

Do Medicaid rules vary by state?

Quick Answer

Medicaid rules are different in every state, especially whether adults without children can get it. In 10 states, there's a 'coverage gap' where some low-income adults can't get Medicaid or Marketplace help.

Details

Yes — Medicaid eligibility rules, income thresholds, covered services, and enrollment processes vary significantly by state, with the most important divide being whether the state has expanded Medicaid under the ACA.

Exceptions: Wisconsin does not have a coverage gap despite not fully expanding Medicaid — it covers adults up to 100% FPL through a different mechanism. Wisconsin also covers some adults without children. Georgia has a work-requirement-based partial expansion.
Escalate If: A consumer is in a non-expansion state with income below 100% FPL and faces the coverage gap, or their Medicaid was recently terminated and they need to quickly determine whether they qualify for a Marketplace SEP.
5
Subsidies

Can subsidy rules vary by state?

Quick Answer

In most states your subsidy is determined by federal rules, but California, Colorado, Connecticut, Maryland, Massachusetts, and New Mexico are also providing extra state help in 2026 — so your subsidy amount depends on where you live.

Details

Yes — while federal subsidy formulas apply nationally, some states have added their own state-funded subsidies on top of federal APTC, meaning subsidy amounts and eligibility thresholds can differ significantly by state for 2026.

Exceptions: State subsidies are funded year-to-year and may not extend beyond 2026. New Mexico's state subsidies may also sunset if Congress restores federal enhanced credits.
Escalate If: A consumer in one of the six subsidy-providing states is being quoted premiums without accounting for the state subsidy layer, or a consumer is confused about whether they are receiving both federal and state assistance.

Chapter 21: Marketing Compliance

1
Agent Help

What should agents avoid promising about ACA plans?

Quick Answer

Agents should never make promises about what a plan covers, what it costs, or what subsidies will be before actually looking it up with current data. If you're not sure, say so and look it up.

Details

Agents must never promise specific premium amounts, guaranteed coverage of specific doctors or drugs, guaranteed subsidy amounts, or specific benefits from a plan without verifying current, official plan data — all such representations must be based on documented, current facts.

Exceptions: Agents can describe how plans generally work, what the ACA requires plans to cover (EHBs), and how the subsidy formula works — these are educational statements, not representations about a specific plan's specifics.
Escalate If: An agent realizes they may have made an inaccurate promise to a consumer (e.g., told them a specific doctor was in-network without verifying) — this should be corrected immediately and documented before enrollment is finalized.
2
Agent Help

Can an agent guarantee that a doctor is in network?

Quick Answer

Agents can't promise a doctor is covered — networks change. Always have the client call the doctor's office or check the plan's official directory before enrolling, especially if a specific doctor is the reason for choosing that plan.

Details

No — an agent cannot guarantee that any specific doctor is in-network. Agents must direct consumers to verify provider status directly through the plan's official provider directory or by calling the provider's office.

Exceptions: Emergency care must be covered at in-network rates regardless of whether the emergency provider is in-network. For non-emergency care, there is no such protection without in-network status.
Escalate If: A consumer is selecting a plan primarily because they believe a specific specialist, hospital system, or treatment center is in-network — agents must flag this as a high-stakes verification need and recommend the consumer directly call both the provider and the plan before enrolling.
3
Agent Help

Can an agent guarantee a medication will be covered?

Quick Answer

Agents can't promise a specific drug will be covered. Always check the plan's drug list (formulary) before enrolling, especially if the medication is expensive or there are no good alternatives.

Details

No — an agent cannot guarantee that a specific medication will be covered or at what cost-sharing tier. Formularies change annually (and sometimes mid-year), and coverage depends on the plan's current formulary, tier, and any applicable prior authorization or step therapy requirements.

Exceptions: ACA plans must cover at least one drug in each formulary therapeutic class, but they are not required to cover every drug. Some drugs — such as cosmetic or over-the-counter medications without a prescription — may not be covered at all.
Escalate If: A consumer is on an expensive specialty medication (e.g., biologic, antiviral for HIV, immunosuppressant) that is critical for managing a chronic or life-threatening condition — drug coverage verification should be completed before enrollment is finalized, not after.
4
Subsidies

How should agents discuss subsidies responsibly?

Quick Answer

When talking about subsidies, use the actual numbers from the Marketplace — not guesses. Always explain that the amount could change based on actual income at tax time, and never inflate the estimate to make a plan look cheaper.

Details

Agents should discuss subsidies in terms of how the formula works, run accurate estimates using current Marketplace tools, make clear that estimates are based on provided income and may change at tax reconciliation, and never guarantee a specific dollar amount.

Exceptions: Agents should be especially careful in 2026 given the major change from 2021–2025 (when enhanced credits had no income cap) to 2026 (when the cliff at 400% FPL has returned). Many consumers may have incorrect expectations based on prior-year experience.
Escalate If: A consumer's income is near the 400% FPL cliff and a small income change in either direction significantly changes their subsidy — this should be discussed carefully with an acknowledgment of the uncertainty, and the consumer should be advised to update income mid-year if it changes.
5
Agent Help

Can agents choose a plan for the client without discussion?

Quick Answer

Agents cannot pick a plan and sign someone up without that person's clear agreement. The client must review the application and choose the plan — the agent is there to help, not to decide.

Details

No — agents cannot choose a plan for a client without their knowledge and consent. CMS requires that agents obtain consumer consent, review the application with the consumer for accuracy, and have the consumer affirm their plan selection before submitting.

Exceptions: If a consumer designates the agent as an authorized representative with specific authority to act on their behalf in limited circumstances, that authorization must still be documented and cannot extend to making decisions the consumer has not been informed about.
Escalate If: An agent discovers that another agent has enrolled a consumer in a plan without that consumer's knowledge or consent — this is a compliance violation that must be reported to CMS and the state department of insurance immediately.

Chapter 22: Agent Workflows

1
Workflow

What is a good first-call ACA intake workflow?

Quick Answer

Start every call by getting permission, finding out where the client lives, who's in their household, their income, and whether they have any other insurance — that information shapes everything that comes next.

Details

A strong first-call ACA intake workflow covers: confirm consent, gather basic household and income data, determine state and enrollment window, screen for SEP or OEP, check for employer coverage or Medicaid eligibility, then compare plans before discussing options.

Exceptions: Clients calling during the OEP have the most flexibility. Clients calling outside OEP with a complex SEP situation may need Marketplace verification of the qualifying event before proceeding to plan comparison.
Escalate If: The consumer describes a complex household structure (e.g., divorce in progress, mixed-status household, dependent with a disability who may qualify for separate Medicaid), a prior unauthorized enrollment, or a gap-in-coverage situation requiring immediate resolution.
2
Agent Help

What key facts should an agent gather before discussing plans?

Quick Answer

Before showing a client any plans, you need their zip code, everyone in the household, their income, their current insurance, and what health care they use — you can't find the right plan without all of this.

Details

Before discussing plans, an agent should gather: state of residence and zip code, all household members and their ages, projected 2026 annual income (MAGI), current insurance status and end date, any qualifying life events, employer coverage offers, and any specific health care needs (doctors, medications).

Exceptions: For a general educational conversation (not leading to enrollment), full SSNs and exact income are not needed. However, for any actual Marketplace application or plan comparison tied to a specific application, all of the above must be gathered.
Escalate If: The consumer is unable or unwilling to provide key information (e.g., won't provide income, has unclear immigration status, or has household members whose tax filing situation is complex) — proceeding without complete information creates subsidy reconciliation risk for the consumer.
3
Agent Help

How should an agent screen for SEP eligibility?

Quick Answer

Ask the client if anything major happened in the last 60 days — lost insurance, got married, had a baby, moved. Any of those events might give them a special window to sign up for coverage even outside Open Enrollment.

Details

To screen for SEP eligibility, ask about any recent life changes: job loss, marriage, birth/adoption, move, loss of Medicaid/CHIP, or other coverage changes. If a qualifying event occurred within the past 60 days (or is expected within 60 days), the consumer likely has an SEP.

Exceptions: Loss of grandfathered or grandmothered plans, transitional plans, or coverage that is not 'minimum essential coverage' under the ACA may or may not trigger an SEP — verify with the Marketplace. Also, voluntary cancellation of individual market coverage does not generally trigger an SEP.
Escalate If: A consumer believes they have a qualifying event but the Marketplace rejects their SEP request or requires documentation the consumer cannot produce, or if the consumer is facing a coverage gap while the SEP is being verified.
4
Agent Help

How should an agent screen for employer-coverage issues?

Quick Answer

Ask if the client's employer offers health insurance and what the monthly cost is. If the employer's plan is affordable (under about $132/month for self-only in 2026), the client probably can't get a subsidy on the Marketplace.

Details

Ask whether any household member currently has access to employer-sponsored coverage, what the employee-only monthly premium is, and whether the plan provides minimum value. These facts determine subsidy eligibility even if the consumer prefers a Marketplace plan.

Exceptions: The 2022 'family glitch fix' allows family members to get Marketplace subsidies even if the employee-only premium is affordable, as long as the full family premium is unaffordable relative to household income. Verify using the Marketplace application.
Escalate If: The consumer is unsure whether their employer plan provides minimum value (ask for the plan's Summary of Benefits and Coverage), or the consumer is in a COBRA situation where the COBRA premium may or may not be affordable compared to the Marketplace.
5
Medicaid

How should an agent screen for Medicaid or CHIP possibilities?

Quick Answer

Before showing someone Marketplace plans, check whether they or their household might qualify for free or low-cost Medicaid or CHIP — especially if their income is below about $22,000 for one person or $45,000 for a family of four.

Details

Screen for Medicaid and CHIP by asking about household income relative to FPL and household members' ages. In the 40 Medicaid-expansion states, adults at or below 138% FPL generally qualify for Medicaid; children and pregnant individuals may qualify at higher income levels through CHIP.

Exceptions: Lawfully present immigrants with income below 100% FPL who are in the 5-year Medicaid waiting period may qualify for Marketplace PTCs even in expansion states — they are an exception to the rule that below-138% FPL means Medicaid rather than Marketplace.
Escalate If: The consumer reports being recently disenrolled from Medicaid without clear reason (during the post-COVID unwinding), is in a non-expansion state with income below 100% FPL, or has a complex household where some members have Medicaid and others need Marketplace coverage.
First American Insurance
First American Insurance

ACA Knowledge Guide — Quick Reference (110 Q&As)

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