Access Health CT — the state’s health insurance exchange — recently warned that as many as 30 to 35 percent of its 150,000 marketplace enrollees may lose coverage in the coming years as federal subsidies expire and verification rules tighten. The projection quickly circulated through Hartford and has become the latest rallying point for lawmakers insisting that state taxpayers should step in to replace the disappearing federal subsidies.
Before Connecticut commits to spending millions to backfill those subsidies, however, it must answer a foundational question: how many people currently receiving the Advance Premium Tax Credit (APTC) — the Affordable Care Act’s primary subsidy — are actually eligible for it?
That question has become unavoidable in light of a series of alarming findings from the federal Government Accountability Office (GAO), which indicate that the federal verification system responsible for approving APTC is failing at numerous critical checkpoints.
The Real Issue: APTC Verification
The political debate in Hartford is focused on the risk that eligible households may lose financial support as federal rules change. But Connecticut has never released an independent assessment confirming the accuracy of its federally verified subsidy rolls. Instead, the state accepts the federal eligibility determinations because it does not have the ability to authenticate Social Security numbers, citizenship, or tax data on its own.
When Access Health CT warns that 35 percent of enrollees may lose coverage, it assumes that the individuals receiving subsidies today are properly verified. GAO’s findings strongly suggest that this assumption deserves scrutiny. The federal system that determines eligibility has repeatedly approved fictitious applicants, individuals with invalid or reused Social Security numbers, and enrollees who are deceased. If the state’s current enrollment numbers include individuals who should never have been approved, then the projected losses are also overstated.
GAO’s Findings on Federal Verification Failures
GAO examined APTC to understand fraud risks embedded within a program that distributes billions of dollars each year directly to insurance companies. Investigators submitted fictitious applicants using invalid Social Security numbers, false information, or missing documentation, nearly all were approved for subsidized coverage. In 2025 tests, 18 of 20 fake applicants continued to receive more than $10,000 per month in subsidies.
It gets worse.
GAO also identified tens of thousands of Social Security numbers linked to more than 365 days of subsidized coverage — something that is only possible if the same number is being reused across multiple policies. One Social Security number appeared on 125 separate insurance policies, totaling 71 years of cumulative subsidized coverage. More than 58,000 subsidized enrollees matched federal death records, including approximately 7,000 individuals whose coverage began after they died. And in total, GAO was unable to verify the tax information underlying more than $21 billion in APTC issued in 2023.
These failures are not minor inconsistencies. They reveal a verification system that cannot consistently confirm identity, citizenship, income, or even whether an enrollee is alive.
Why Connecticut Is Fully Exposed
Connecticut may operate its own exchange, but APTC is a federal subsidy. Every APTC determination must be verified through the federal Data Services Hub, which checks eligibility against databases maintained by SSA, DHS, and IRS. Access Health CT can request documents and attempt to resolve certain data inconsistencies, but it cannot re-run federal checks, access federal databases directly, or override a federal determination. In practice, the state must rely on the federal system’s determination when granting APTC, even when documentation appears questionable on its face.
This means Connecticut’s APTC rolls are therefore only as accurate as the federal verification system behind them — and GAO’s findings show that the system is deeply flawed.
Rethinking the “35 Percent” Projection
This context matters because the 35 percent estimate refers only to those who receive APTC today. Access Health CT has cautioned that changes in federal law will remove eligibility for categories of legally present non-citizens — including DACA recipients and some recent green-card holders; those individuals are eligible today, but under the new federal rules they will no longer qualify.
At the same time, GAO’s findings show that the federal verification system has also approving applicants who never qualified at all. Without knowing how many subsidy recipients in Connecticut fall into either group, the state cannot treat the 35 percent projection as a reliable measure of legitimate enrollment loss.
The Legislative Response
Some lawmakers have responded to changes in the subsidies by urging the state to replace lost federal subsidies with state funds. Sen. Jorge Cabrera (D-Hamden) argued the state has a “moral responsibility” to do so, while Rep. Kate Farrar (D-West Hartford) called for an emergency fund to offset federal cuts. Both positions assume that current subsidy recipients are correctly verified.
Others have urged caution, in a December 4 statement to Yankee Institute, Senators Stephen Harding and Rob Sampson described GAO findings as “damning,” adding that “the fraud risks are specifically related to the healthcare program’s advance premium tax credit. We will be requesting our bipartisan Auditors of Public Accounts here in Connecticut to review the report and to examine whether any potential fraud might be occurring in our state. It’s our money. It must be safeguarded.”
Why a Review Is Necessary
A state audit would not target low-income residents. It would evaluate the reliability of the federal determinations that Connecticut is required to accept. A review could determine whether Connecticut’s subsidies are going to real, eligible residents or whether the state’s numbers mirror the verification failures GAO uncovered nationally. Ensuring accuracy would allow Connecticut to avoid building a costly new state program on top of potentially flawed data.
Get the Facts Before Spending the Money
Connecticut should not allow families to lose access to coverage unnecessarily. But it also should not commit millions of state dollars without first ensuring that its subsidy program is based on verified and accurate information. Confirming eligibility is not about denying coverage — it is about ensuring that the system is sustainable and that assistance is reaching the people it is intended to help.
If Connecticut is being asked to replace federal subsidies with state funds, the least it should do is confirm that the numbers are trustworthy. Only then can policymakers make informed decisions about whether and how to act.
