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U.S. citizens, U.S. nationals, and non-U.S. citizens with certain immigration statuses can get Marketplace coverage and may qualify for financial assistance.
Effective August 25, 2025, Deferred Action for Childhood Arrivals (DACA) recipients do not qualify for Marketplace coverage or financial assistance.
In this article we'll cover:
Acceptable immigration statuses
The Federally Facilitated Marketplace (FFM) states that lawfully present immigrants with qualifying immigration statuses are eligible for Marketplace coverage and may qualify for financial assistance.
The full list of acceptable immigration statuses is available here and includes:
Lawful Permanent Resident (LPR/Green Card holder)
Asylee
Refugee
Cuban/Haitian entrants
Consumers who have had a change in immigration status since applying for Marketplace coverage should update their Marketplace application with their new immigration status.
Upcoming changes
The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, narrows Marketplace financial assistance eligibility for some lawfully present immigrants.
Separate federal policy changes may also affect whether certain immigrants can enroll in Marketplace coverage.
Some changes may begin in 2026, while broader restrictions are expected to begin in plan year 2027. Implementation details may depend on future federal guidance.
History of recent changes
From November 2024 through August 25, 2025, DACA recipients and individuals in certain other non-U.S. citizen groups were granted eligible immigration status to enroll in Marketplace coverage for plan years 2024 and 2025.
Legal efforts in 19 states blocked this decision, placing Marketplace enrollment on hold for these groups in those states.
The 19 states involved in the lawsuit included:
Alabama
Arkansas
Florida
Idaho
Indiana
Iowa
Kansas
Kentucky
Missouri
Montana
Nebraska
New Hampshire
North Dakota
Ohio
South Carolina
South Dakota
Tennessee
Texas
Virginia
DACA recipients and certain other non-U.S. citizen groups who lived in any of these 19 states were not eligible for Marketplace coverage, even during the November 2024 through August 25, 2025 timeframe.
Of these 19 states, 3 states, Idaho, Kentucky, and Virginia, operated their own State-based Marketplace (SBM). The remaining 16 states operated using the Federally Facilitated Marketplace (FFM).
The Marketplace canceled any 2025 enrollments selected by DACA recipients and other affected non-U.S. citizen groups who resided in those 16 FFM states. Carriers refunded any premiums paid for that 2025 coverage. The Marketplace also sent a letter about ineligibility for coverage to impacted individuals.
For more information, read Recent court decisions impacting the Marketplace on Healthcare.gov.
Tax implications
The Internal Revenue Service (IRS) will consider DACA recipients and other impacted non-U.S. citizens who had 2024 Marketplace coverage in the 19 states listed above eligible for the premium tax credit for the months in 2024 they had coverage, if otherwise eligible.
These consumers will receive Form 1095-A, Health Insurance Marketplace Statement, from the Federal Marketplace or their SBM. Form 1095-A provides information about the consumer’s health coverage and is used to complete Form 8962, Premium Tax Credit.
Impacted consumers must include Form 8962 when filing their 2024 federal income tax return.
Frequently asked questions
What is the difference between a U.S. citizen and a U.S. national?
The Federally Facilitated Marketplace (FFM) defines the difference between U.S. citizens & U.S. nationals here.
Additional resources
For help using HealthSherpa or for other assistance, contact Agent Support. Agent Support is available by phone at (888) 684-1373, by email at Agent_Support@HealthSherpa.com, or by chat directly from your account.