Recent Tax Updates

Federal Marketplace Special 2016 Enrollment Period for Individuals without Marketplace Insurance Due to Failure to File a 2014 Federal Return and Reconcile

February 11, 2016

The Center for Medicare and Medicaid Services (CMS) which runs the Federal Marketplace has announced that there will be a special enrollment period that will run from now until March 31, 2016. This special enrollment period is for individuals previously determined to have been ineligible for the Advance Premium Tax Credit (subsidy) in 2016 because they failed to file a 2014 federal return and did not complete the required reconciliation on Form 8962 (Premium Tax Credit).

The special enrollment period specifically applies to individuals who:

  • Are not currently enrolled in 2016 coverage through the Federal Marketplace;
  • Are not receiving an Advance Premium Tax Credit (APTC) because they failed to file a tax return for 2014 and reconcile their 2014 APTC; and
  • Subsequently filed their 2014 federal tax return and reconciled their 2014 APTC on Form 8962.

The effective date of coverage under this special enrollment period will be the first of the month following the plan selection. Eligible individuals will have access to this special enrollment period through their online application at These individuals will need to return to the Federal Marketplace to update their 2016 application, which includes providing confirmation that they have filed a tax return and reconciled their APTC for Tax Year 2014.

If an individual believes they are eligible for the special enrollment period they need to access their online account on and the Federal Marketplace will inform the individual if they are eligible. The individual will then be provided with instructions to select a plan and complete enrollment.

See the February 5, 2016 CMS Special Enrollment Guidance announcement for more information.