On October 23, 2026, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule entitled, Patient Protection and Affordable Care Act, Exchange Pre-Eligibility Verification. This proposed rule would implement new Affordable Care Act (ACA) Exchange eligibility-verification requirements under H.R.1 (P.L. 119-21), One Big Beautiful Bill (OBBB) / Working Families Tax Cut (WFTC) legislation, including requirements that take effect beginning with plan year 2028. The proposed rule would generally prohibit Exchanges from providing advance premium tax credits (APTCs) and cost-sharing reductions (CSRs) while certain data-matching issues—such as those involving income, family size, citizenship or immigration status, residency, or other health coverage—remain unresolved. However, consumers could enroll in Exchange coverage without financial assistance during this period while verifications are pending. The proposed rule would also require enrollees to provide or confirm key eligibility information annually to continue receiving financial assistance. It would further establish a pre-open-enrollment verification period beginning August 1, 2027, and revise policies governing eligibility redeterminations, coverage effective dates, and special enrollment periods.

The final rule may be found here. The CMS press release may be found here and the CMS fact sheet may be found here.

Impact on General Dentistry: The enhanced eligibility-verification requirements may leave some individuals temporarily uninsured if they are unable to cover the full financial obligations of Exchange coverage while verifications are pending.