|
It’s important to help your clients accurately estimate their income and avoid unexpected costs at tax time. CMS recognizes that you may be getting ready to remind your clients about reconciling advance payments of the premium tax credit (APTC) for Plan Year 2025 when filing their tax returns in early 2026. CMS also wants to make sure that you are aware of future changes around APTC reconciliation rules for Plan Year 2026 and beyond so you can remind your clients to report life changes to the Marketplace in a timely manner throughout 2026.
These two new Frequently Asked Questions (FAQs) address commonly asked questions for APTC repayment starting in Plan Year 2026 (i.e. when consumers are filing their federal taxes in 2027) based on recent legislative changes:
 |
|
Are there limits to how much excess APTC consumers must pay back?
This FAQ clarifies that, beginning with Plan Year 2026 APTC reconciliation (when consumers are filing their taxes in 2027), there is no limitation on excess APTC consumers have to repay when filing their tax return and reconciling their APTC.
View this FAQ.
|
 |
|
Are consumers required to pay back all of their APTC if they estimated their household income to be 100% or more of the FPL but their actual household income ends up being less than 100% of the FPL?
This FAQ clarifies that if consumers did not intentionally or recklessly misrepresent their household income when enrolling in the coverage, Internal Revenue Service (IRS) rules state that this consumer may still qualify for and claim the premium tax credit on their tax return even when the household income as reported on their tax return is below 100% of the FPL.
View this FAQ.
|
Thank you for working with your clients to remind them to report life changes to the Marketplace in a timely manner throughout 2026. Consumers are required to report changes that affect their eligibility for Marketplace coverage and financial assistance, including changes related to their household income, family size, and offers of other health coverage. Additionally, consumers may want to consider accepting less APTC during Plan Year 2026 (which means they would pay a higher monthly premium amount to the issuer) in order to reduce the risk of having a tax liability when they file their federal income taxes for Plan Year 2026 in 2027.
Have questions? For additional assistance, contact the Agent/Broker Email Help Desk via email at FFMProducer-AssisterHelpDesk@cms.hhs.gov.
|
