Background

Data Matching Inconsistencies (DMIs) occur when the information provided by an applicant does not match data from federal or state databases. DMIs help ensure eligibility determinations are based on accurate, verified information. When a data matching inconsistency occurs, MN-EES will automatically trigger an eligibility notice that includes a request for verification, and a notification requesting additional documents will be prominently displayed on the consumer’s dashboard. 

Consumers who have a DMI triggered upon the submission of a new application have 95 days to comply with the request for verification, known as the reasonable opportunity period (ROP). Failure to submit the required documents by the deadline will result in a loss of coverage or financial assistance, depending on the type of verification requested. 

MNsure’s new guide, /assets/DMI_ROP_Assister_Resource_tcm34-773069.pdfData Matching Inconsistencies (DMIs) and Reasonable Opportunity Periods (ROPs), explains the process for consumers and how you can use your MNsure portal to proactively identify clients with an outstanding DMI and those whose ROP have expired. 

Immediate Action Needed

During the process of migrating consumer applications into MN-EES in late June 2026, some consumers had DMIs triggered that required verifications to be submitted within 95 days. If the consumer failed to confirm the accuracy of their information, they received notice in early October that they will be losing financial assistance, and potentially coverage, effective November 1. 

Identifying DMIs and requiring documentation has always been a program requirement, but the transition to MNsure’s new system automated the process. This is an important compliance improvement that protects consumers from receiving benefits they are not eligible for. 

However, MNsure is concerned about the number of consumers who did not act before their ROP ended. We have issued a new notice to impacted consumers, letting them know what steps they can take to reinstate their coverage retroactively, or prospectively reinstate tax credits. MNsure is also directly reaching out to consumers, prioritizing those who are losing coverage.

You can use your MNsure portal to identify any impacted clients (refer to the /assets/DMI_ROP_Assister_Resource_tcm34-773069.pdfData Matching Inconsistencies (DMIs) and Reasonable Opportunity Period for more information) and help the consumer take the following actions:

Steps for consumer losing coverage effective November 1, 2026 (view /assets/ROP_Eligibility_final_tcm34-773070.pdfsample notice):

• Contact the consumer and assist them with editing their application online to review all information and update any information that has changed. 
• Resubmit the application to have eligibility updated.
• DO NOT take any enrollment actions online. Contact MNsure (ARC or Broker Service Line) to review the consumer’s enrollment options. MNsure is offering impacted consumers a special enrollment opportunity. Consumers are eligible for plan reinstatement or a prospective effective date.
• Upload any documents needed to verify their information. 
• The consumer must act no later than December 31, 2026, to have coverage through MNsure effective November or December 2026. 

Steps for consumers losing financial assistance effective November 1, 2026 (view /assets/ROP_Subsidies_final_tcm34-773071.pdfsample notice):

• Contact the consumer and assist them with editing their application online to review all information and update any information that has changed. 
• Resubmit the application to have eligibility updated.
• DO NOT take any enrollment actions online. Any changes to the consumer’s eligibility for premium tax credits will automatically be applied to their 2026 premiums. 
• Upload any documents needed to verify their information.
• The consumer must act by October 31, 2026, to see if they are eligible for tax credits starting November 1. They must act between November 1 – November 30, 2026, to see if they are eligible for tax credits starting December 1.