New ACA Enrollment Rules for Agents: What Changes for 2027
CMS is pausing new ACA agent registrations, requiring verified SSNs on every assisted application, and adding a new electronic client-authorization step before Open Enrollment 2027. Here's what's new, what hasn't changed, and how to track it.
What changes for ACA agents on November 1, 2026 For the plan year that opens on November 1, 2026 , CMS is enforcing three things agents and brokers haven't dealt with before: a pause on new Marketplace agent registrations, a verified Social Security number or immigration document number on every agent-assisted application, and a new electronic authorization step that most enrollment platforms must collect from the client before an agent can act on their application. None of this replaces the consent and three-way-call rules agents already follow — it sits on top of them. Why CMS tightened the rules this year CMS has spent 2026 cracking down on what it calls "unauthorized enrollments" — Marketplace policies created or changed by an agent or broker without the consumer's knowledge. In its September 2026 interim final rule , CMS says it issued notices of intent to terminate to 100 agents and brokers in July 2026 and another 469 in August 2026, after finding implausibly high rates of applications submitted without a valid applicant Social Security number. On August 31, 2026, CMS canceled roughly 315,000 plan year 2026 policies covering more than 760,000 people it determined were enrolled without verified citizenship or immigration documentation, and it says it's reviewing another 440,000 enrollments for similar issues. A CMS newsroom release on the crackdown cites the same 569 notices of intent to terminate. None of that is a reason to panic about a book built the right way. It is the reason every agent-assisted ACA application now gets more scrutiny, and why the three changes below are worth building into your workflow before Open Enrollment, not during it. Three things that are new for plan year 2027 1. A pause on new agent and broker registration The same interim final rule imposes a temporary moratorium, effective September 22, 2026 and running through February 1, 2027 , on registering new Marketplace agents and brokers who did not hold a plan year 2026 Exchange agreement. If every producer at your agency already had an active 2026 Exchange agreement, the moratorium doesn't touch you — but you still need to complete plan year 2027 registration and training through the CMS Marketplace registration and training page , which offers a shorter training path for agents returning from 2026. If your agency is planning to bring on a brand-new ACA producer who has never held a federal Exchange agreement, that registration is on hold until the moratorium lifts (or CMS changes it), so recruiting timelines need to account for that now. 2. A verified SSN or immigration document number on every assisted application The same rule states plainly: "all applications involving an agent or broker must include verifiable Social Security Numbers or immigration document numbers that CMS can verify for all non-newborn applicants." CMS's own data point, from the same document, is that fewer than 1% of applications submitted without agent help were missing that information — so an agent-assisted application that's missing it now stands out. Practically, that means an application you help a client submit without a verifiable SSN or immigration document number (newborns excepted) is a flag CMS is actively watching for, not a paperwork detail to clean up later. 3. Electronic consumer authorization before you can act on an application This is the one most agents haven't seen yet. Under EDE Change Request 109 , announced by CMS on May 27, 2026, every Enhanced Direct Enrollment (EDE) platform must "systematically enforce consumer identity proofing and get agent/broker authorization from the consumer for applications or enrollments submitted through the EDE agent/broker pathway" ahead of the 2027 Open Enrollment Period. In practice, the platform contacts the consumer directly — by text, email or an automated call — with a one-time passcode or confirmation link that expires in 15 minutes, and it will not send more than three of those notices in 24 hours for a given application. If the consumer doesn't respond, CMS's own FAQ says the platform "may allow agents to manually send a second or third notification," but beyond that, you're waiting on the client, not pushing past them. CMS also notes agents can get ahead of this by identity-proofing existing clients proactively, before Open Enrollment opens, so the authorization is already on file when you need to touch their application. What hasn't changed Two long-standing requirements are easy to confuse with the items above, but they're separate and they're still in force. First, agents must already document a consumer's consent before accessing their information or assisting with a Marketplace application or enrollment — CMS lays out what that documentation needs to cover in its Marketplace Compliance for Agents and Brokers guide. Second, if you're helping a client who isn't already associated with your National Producer Number on their enrollment, CMS's standing rule is that you either direct them to make the change themselves through HealthCare.gov or an approved enrollment platform, or you get on a three-way call with the client and the Marketplace Call Center so the change is made with the consumer present — a requirement CMS restates in its statement on system changes to stop unauthorized agent and broker activity . The new electronic authorization step doesn't remove that call; it adds a second checkpoint earlier in the process, for a different set of actions. A before-November-1 checklist Run this with your producers before Open Enrollment opens, not during the first week of it: Confirm every ACA producer's plan year 2026 Exchange agreement was active, so you know who is and isn't affected by the registration moratorium. Confirm plan year 2027 registration and training is complete for every returning producer, using CMS's registration page. For any client you're about to enroll or renew, confirm you have a verifiable SSN or immigration document number on file before you submit — not a placeholder, and not "the client said they'd send it." Know which of your enrollment or EDE platforms now sends electronic authorization requests, and make sure your clients' phone numbers and email addresses on file are current so those texts and links actually reach them. If you're changing the agent of record on an existing client who isn't already tied to your NPN, plan for the three-way call — don't assume a note in the file is enough. Keep your existing consent documentation retrievable per client, not just saved somewhere once and forgotten. Where this actually lives in your CRM Most of the above is a documentation and follow-up problem, which is exactly what a CRM is for if you set it up that way. AgencyView runs ACA Marketplace quoting through HealthSherpa directly from the client record, and selecting a plan there creates a pending policy on that contact automatically — so there's one record of who you quoted and when, not a separate spreadsheet. When a consent form, an authorization record or any other document needs to be collected or kept, AgencyView's Submissions Center stores it filed to that contact, and Request Documents lets you text a client a link to send it back, instead of chasing a signature through email. Every open of a stored document and every access to the record is written to the audit log that AgencyView's HIPAA audit trail already keeps, so if CMS or a client ever asks when a form was filed or who looked at a record, the answer is there instead of reconstructed from memory. The harder part is catching the clients who fell through the cracks — the ones who were enrolled, then stopped responding to an authorization request, or whose coverage CMS flagged for a reason you don't find out about until a client calls confused that their policy is gone. That's what AgencyView's ACA Marketplace Book of Business report is for: it reconciles your actual HealthSherpa export against your CRM contacts and your commission…
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