Who can get the ACA tax credit in 2027?
Starting with 2027 coverage, P.L. 119-21 (section 71301) limits the premium tax credit to citizens, nationals and three groups the law calls eligible aliens. CMS’s Oct. 5, 2026 guidance applies the same limit to the extra savings on silver plans (cost-sharing reductions).
| Status | Can buy a Marketplace plan | Tax credit and extra savings in 2027 |
|---|---|---|
| Citizen or national | Yes | Yes |
| Green card holder (lawful permanent resident) | Yes | Yes |
| Cuban or Haitian entrant | Yes | Yes |
| COFA migrant: a citizen of the Marshall Islands, Micronesia or Palau living in the United States | Yes | Yes |
| Refugee or asylee | Yes | No, full price |
| Temporary Protected Status, parole, a work permit, a student or work visa, or another lawful status | Yes | No, full price |
| DACA recipient | No | No |
| No lawful status | No | No |
Everyone who gets the credit still needs household income from 100% to 400% of the poverty line, shown in the 2027 federal poverty level chart, and must meet the other rules, such as not qualifying for Medicaid. HealthCare.gov’s immigration status page lists every status that can buy a plan.
What changed from 2026?
Through 2026, any lawfully present immigrant could get the tax credit. For tax years beginning after Dec. 31, 2026, only the groups above can. Two other parts of P.L. 119-21 already took effect:
- Section 71302, from 2026: lawfully present immigrants with income under 100% of the poverty line no longer get the credit when their status keeps them off Medicaid.
- Section 71109, from Oct. 1, 2026: federal Medicaid and CHIP funds cover only citizens, nationals, green card holders, Cuban and Haitian entrants and COFA migrants, with exceptions such as emergency Medicaid.
Most green card holders still wait 5 years for Medicaid, according to HealthCare.gov, and some don’t, such as former refugees and asylees. During that wait, a green card holder with income of at least 100% of the poverty line can get the tax credit instead.
What happens to people already enrolled?
CMS’s guidance sets these steps for HealthCare.gov enrollees who aren’t citizens:
- HealthCare.gov checks each person’s status with the Department of Homeland Security’s SAVE system.
- If it confirms green card, Cuban or Haitian entrant, or COFA status, savings continue in 2027 for a household that otherwise qualifies.
- If it can’t confirm one, the Marketplace’s open enrollment notice says savings end unless you act, and an eligibility notice before Jan. 1 explains your appeal rights.
- If you don’t update your application by Dec. 15, 2026, HealthCare.gov re-enrolls you on Jan. 1, 2027 in a plan without savings, at full price.
- If you don’t want a full-price plan, cancel your 2027 coverage before it renews.
Enrollees who lose the tax credit also lose the 3-month grace period for late premiums. The insurer’s own grace period applies instead. Every 2027 deadline is in 2027 open enrollment dates.
What if HealthCare.gov can’t verify your status?
New applicants state their status, and HealthCare.gov checks it with SAVE. If SAVE can’t confirm an eligible status, you get a data matching issue and 95 days to send documents, such as a Permanent Resident Card, an Employment Authorization Document or an I-94 record. HealthCare.gov’s document list covers each status.
You can enroll and keep the tax credit during those 95 days if you otherwise qualify. Documents that show a lawful status outside the four groups end the savings. Documents that don’t show lawful presence end the coverage.
How is the credit figured for a mixed-status family?
The tax credit law (26 U.S.C. 36B(e)) takes members who aren’t eligible out of the credit in two places:
- Premiums: the plan’s premium and the benchmark plan’s price count only the eligible members, so the credit pays only toward their coverage.
- Income test: the share of the poverty line is figured with those members left out of family size and household income scaled by the ratio of the two poverty lines.
The income test gives the same share of the poverty line as counting everyone. Coverage Decider worked an example from the 2026 HHS guidelines: a family of three expects $45,000 in 2027, and one parent has Temporary Protected Status. Scaled income is $35,644 ($45,000 times $21,640 divided by $27,320, rounded to the nearest dollar), which is 164.7% of the line for two. That’s the same 164.7% that $45,000 is for three, so the household’s percentage from the IRS table is the same too.
The IRS’s proposed rules of Oct. 15, 2026 spell out the premium split. CMS says Form 1095-A for 2027 may leave out the premiums of members who aren’t eligible.
How does Coverage Decider handle immigration status?
Coverage Decider’s calculator asks a status only for people who aren’t citizens or nationals. The choices are green card, Cuban or Haitian entrant, or COFA migrant; refugee, asylee or other lawful status; DACA; no lawful status; or prefer not to say. The calculator counts only eligible members’ premiums toward the credit, and it doesn’t save immigration answers. How Coverage Decider calculates lists the rules it uses.
HealthCare.gov makes the final decision. Free local help can check your documents and your application before Dec. 15.