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Reducing Data Matching Issues Before Pre-Enrollment Verification Takes Effect

Five ways marketplaces can use 2027 to prepare for a change that makes documentation a condition of coverage.

By Sarah Baggé, VP, ACA Marketplace Policy and Communications, IdeaCrew
September 2026

Marketplaces will face the biggest policy change in their 12-year history in 2027 as they implement Pre-Enrollment Verification (PEV). Section 71303 of the One Big Beautiful Bill Act (also known as H.R. 1) passed in July of 2025 fundamentally redesigns the eligibility determination and enrollment process by requiring most of a consumer’s information to be verified before they start receiving the subsidies.

Background

Marketplaces have always been required to compare key information a consumer puts on their eligibility application with electronic data sources. If the data sources don’t match the information the consumer provided (for example, if their most recent tax return shows income that was significantly higher than they reported), the marketplace creates a Data Matching Issue or DMI. The DMI gives the consumer 90 days in which to upload documents that prove their eligibility. Most importantly, consumers can enroll in coverage and use subsidies during those 90 days.

Processing DMIs has always been a substantial source of work for marketplaces. Marketplace or call center staff must review uploaded documents and take action to update consumer information and adjust subsidies accordingly. This may involve back and forth if, for example, the documents the consumer uploads are incomplete. And research has shown that the consumers most likely to forgo coverage because of administrative barriers like uploading documents are the young, healthy people with low healthcare needs that are crucial for viable insurance risk pools.1

How PEV changes things

PEV flips the current sequence on its head by requiring consumers to resolve most DMIs before they can receive subsidies. What was once a task to complete after enrollment now becomes a barrier to accessing affordable coverage in the first place. Since 87 percent of those enrolled on the marketplaces rely on these subsidies to pay a portion of their premiums, the impact is significant.2

This makes DMIs will more important than ever. As marketplaces plan to implement PEV during 2027 for the 2028 coverage year, they should also think about ways to reduce unnecessary DMIs and automate processing to get consumers the affordable coverage they need as quickly as possible. This article highlights five areas marketplaces can consider to reduce their DMI burden.

These are policy decisions and system decisions at the same time. Where a reasonable compatibility threshold gets set, which data sources get called, and how a document upload fits into the application flow are all decided twice: once in policy and once in configuration. Marketplaces that collaborate on those decisions, with policy staff and engineers in the same conversation, will get further faster than those that hand them off in a linear workflow.

Ideas to improve outcomes

Preventing DMIs

The best DMI is one that never gets created, so the first three areas focus on ways to prevent DMIs from being created in the first place.

  1. Increase the rate of successful verifications

Checks of electronic data sources rely on key pieces of personal information (for example, name, date of birth, Social Security number, and immigration document numbers) to match a consumer against database records. Marketplaces can take simple steps to improve the quality of this key information, resulting in a higher success rate of electronic data source calls. Places to look include:

  • Requiring double entry of numbers such as Social Security numbers to reduce input errors
  • Leveraging real-time services that give consumers an opportunity to re-input information while they are still in the application if an initial data source call doesn’t return a match
  1. Extend acceptable response thresholds and acceptance of attestations

Federal regulations give marketplaces some flexibility on what data service checks to require, and how much a consumer’s application information can differ from what’s in a data source and not require a DMI. Marketplaces can consider:

  • Accepting self-attestation for state residency, incarceration, and American Indian/Alaska Native tribal membership
  • Increasing their income reasonable compatibility thresholds

Ultimately, each marketplace will need to find the right balance of removing administrative barriers while maintaining program integrity.

  1. Implement additional data sources

Regulations mandate the use of specific data sources like the Internal Revenue Service (IRS) and Social Security Administration (SSA), but marketplaces are encouraged to leverage additional available data sources as well. One key area for this is income. Marketplaces must check the latest available tax data, but this information is frequently out-of-date, particularly given that many marketplace enrollees are self-employed or have variable incomes. Marketplaces that do not already use them should consider creating calls to:

  • The Verify Current Income service provided as part of the Federal Data Services Hub (though there is a usage cost associated with this service)
  • State quarterly wage databases

Resolving DMIs Faster

  1. Increase the rate at which consumers provide documents

Once a DMI is created, marketplaces should think creatively about how to ensure as many consumers provide documents as possible. Options to explore include:

  • Modifying workflows to make providing documents a step that’s attached to completing an application or enrolling in a plan
  • Outreach to consumers with DMIs through a variety of means, including paper notices, text messages, and phone calls
  • Using AI agents to do targeted outreach and walk consumers through the document upload process3
  1. Automate document review using AI

AI also offers opportunities to automate some of the tasks of document review. Using AI to review documents does not have to be an all-or-nothing proposition. AI can extract key data from documents provided, make calculations, and recommend a course of action along with a confidence score. Marketplace or call center staff can then review and make the final decision.

Marketplaces have lots to think about on their 2027 roadmaps, but making DMI reduction a priority will pay off with more consumers able to access affordable coverage without barriers.

  1. https://www.aeaweb.org/articles?id=10.1257/aer.20231133 ↩︎
  2. https://www.healthsystemtracker.org/brief/how-much-and-why-aca-marketplace-premiums-are-going-up-in-2027/ ↩︎
  3. https://kffhealthnews.org/medicaid/medicaid-work-requirements-medi-cal-ai-agents-reenroll-careforce-california/ ↩︎

Sep 14, 2026

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