As of October 12, 2026, the steps for enrolling in ACA coverage through an Enhanced Direct Enrollment (EDE) agent or broker pathway have changed. The agent now needs the consumer’s explicit authorization before proceeding. An insurance agent license lookup can help establish who the agent is before that authorization is given.
What Changed on October 12, 2026
According to CMS’s new guidance, all applications and enrollments submitted through the EDE agent/broker pathway require affirmative agent/broker authorization from the consumer. Without it, the agent is blocked from proceeding.
Authorization confirms that the consumer permits a specific agent to act on an application or enrollment. Identity proofing is a separate step used to confirm the consumer’s identity. For applications CMS classifies as high risk, identity proofing must be completed first.
The change applies to the federal platform and State-Based Exchanges using that platform. CMS says the FFE and SBE-FP platform serves 29 states. State-run marketplaces that do not use the federal platform may have different requirements.
The practical effect is a shift in control: instead of relying only on an agent’s access, the consumer must actively approve the individual agent’s role. Authorization is required once per plan year, per agent, per EDE platform. A consumer generally needs to authorize an existing agent again for 2027. Only one agent user ID may be associated with an application at a time.
Who Gets Identity Proofed First
CMS identifies three high-risk triggers. Identity proofing must occur before authorization is collected when an application involves:
- A new consumer application, including a person seeking coverage in a different coverage state.
- At least one active enrollment, excluding stand-alone dental, with a net premium of $30 or less per month after advance premium tax credits.
- A consumer working with a new or different agent.
Other applications are classified as low risk. They still require a lightweight authorization step, such as a one-time passcode or confirmation link. The agent cannot proceed through the EDE agent/broker pathway without that affirmative approval.
For example, a 55-year-old in Texas applying for Marketplace coverage for the first time may be asked to complete identity proofing before approving an agent, even if the person expects to pay the full premium. The new-application trigger applies independently of whether the person receives a tax credit. The person should compare the premium and coverage details shown for the application rather than assume a subsidy or price.
What You Will Actually See This Fall
EDE platforms may contact consumers by text, email, or automated phone call. The exact interface can vary by platform. CMS requires links and passcodes to be single use and expire within 15 minutes. No more than three notifications may be sent in 24 hours for a given agent user ID and application ID.
A returning member whose existing agent is helping with a 2027 application or plan change may receive a request to authorize that agent for the new plan year. A passive automatic renewal with no agent action is different; if an agent actively uses the EDE agent/broker pathway, the annual authorization applies.
A consumer working with a different agent may be asked to prove identity first, then approve that specific agent. If the person who calls is not the person listed for authorization, the EDE process should not be treated as permission for the caller to proceed.
Complete a passcode or link only from a device under the consumer’s control, after checking that the request corresponds to the agent and application expected. Do not give the code to an agent or read it aloud. Do not follow an unexpected link or authorize an unfamiliar person.
CMS’s new authorization does not replace the separate requirement for documented consumer consent under 45 CFR 155.220(j)(2)(iii). The CMS consent and application review FAQ explains that consent must still be obtained and documented before an agent accesses or searches for a consumer’s information. Consent records must be retained for at least 10 years. Agents must not enter their own phone number, email, or address on a consumer’s application, and must never log in to the consumer’s HealthCare.gov account.
Why This Rule Exists: Unauthorized Enrollments and Plan Switching
The change is a program-integrity measure, not just an additional form step. The September 2026 Federal Register rule paused new agent and broker registrations on the federal marketplace through February 1, 2027, for people without a 2026 federal exchange agreement. It also reported that CMS canceled approximately 315,000 2026 policies covering more than 760,000 people after consumers could not be contacted and required citizenship or immigration documentation had not been verified.
For consumers, an unauthorized plan change can affect premiums, doctors, prescriptions, and the coverage relied on for care. The federal registration pause does not establish that every online profile or social-media account presenting as an agent is qualified. It makes independent identity and license checks important.
For Open Enrollment 2027, CMS is also sunsetting the July 2024 InvalidAction error and the three-way-call workaround. Agents will be able to make plan switches and NPN changes directly on the platform after identity proofing and authorization. The Marketplace Call Center will no longer accept application or enrollment changes requested by an agent. Direct platform access removes the old call requirement, not the need for the consumer’s authorization and documented consent.
How to Verify an Agent Before You Authorize Them
Use an insurance agent license lookup by the agent’s name or National Producer Number (NPN) as an initial check. The NPN identifies a producer nationally; it is not the same as a state license number. Compare the agent’s name and NPN on the profile with the information provided by the person requesting authorization.
VerifiedAgent’s directory includes agent profiles, recorded license states, insurance categories, and customer reviews. Start with the Texas insurance agent directory or the Florida insurance agent directory, or browse the state directory to find licensed agents in your state. Directory details should be independently confirmed with the relevant state insurance department. Licensing procedures and requirements vary by state, and a directory listing is not a guarantee of current licensure, Marketplace registration, or enrollment authority.
Before approving the request:
- Confirm the agent’s full name and NPN in writing.
- Confirm state licensure for the state where coverage is sought.
- Check that the request is for the 2027 plan year and the correct EDE platform.
- Review available customer feedback as one source of information, not proof of license or authorization.
- Confirm which individual agent will work on the application. CMS identifies listing the writing agent’s name and NPN as a best practice.
For consumers comparing ACA coverage for 2027, or checking whether financial assistance may apply, getaca.com provides ACA Marketplace enrollment information.
Five Questions to Ask Before You Authorize an Agent
- What is your full name, NPN, and state license number? Request the information in writing and compare it with directory and state records.
- Which states are you licensed in, and are you authorized on this EDE platform for the 2027 plan year? Confirm the state and platform match the application.
- What will my monthly net premium be after any advance premium tax credits? Ask which income and household information the estimate uses.
- What are the plan’s deductible and maximum out-of-pocket amount? Confirm these alongside the network, prescriptions, and effective date.
- How can I rescind authorization or consent, and what compensation do you receive? Ask for the rescission process and a clear description of compensation.
If an Agent Enrolled You Without Your Permission
- Check your Marketplace account and current plan information. Note any unfamiliar agent, plan, premium, or application change.
- Call the Marketplace Call Center at 1-800-318-2596 to report the issue and ask what steps are available to review or correct the enrollment.
- Report suspected unauthorized search, enrollment, or CMS-system access to [email protected].
- Contact the insurance department in your state to ask about a licensing complaint or other state process.
- Save unexpected texts, emails, call details, and enrollment notices. Do not provide personal information or a verification code to an unfamiliar caller. Check directly with the insurer whether coverage is active and what plan is recorded.
If a caller claims to be the agent but is not the person the consumer intended to authorize, do not approve the request on the caller’s behalf. Confirm the agent’s identity through a contact method obtained independently.
What It Means After Enrollment: Key Dates
The HealthCare.gov enrollment calendar lists ACA Open Enrollment for 2027 as November 1, 2026, through January 15, 2027. Enroll by December 15 for coverage beginning January 1. Medicare’s Annual Enrollment Period begins October 15 and ends December 7; it is separate from ACA Marketplace enrollment.
Timeline: October 15, Medicare AEP begins; November 1, ACA Open Enrollment begins; December 7, Medicare AEP ends; December 15, ACA deadline for January 1 coverage; January 15, final ACA Open Enrollment deadline.
FAQ
Do all ACA applicants have to complete identity proofing before approving an agent?
No. CMS requires affirmative agent/broker authorization for all applications submitted through the EDE agent/broker pathway. Identity proofing must come first for the high-risk categories. Other applications may use a lightweight method, such as a one-time passcode or confirmation link, to capture authorization.
Does authorization replace an agent’s consent documentation?
No. Authorization is a separate EDE requirement. The existing federal consent requirement remains in effect. Agents must obtain and document consent before accessing consumer information or searching for an application, and must retain required consent records for at least 10 years.
Will a returning Marketplace member need to approve the same agent again?
Usually, if the agent is using the EDE agent/broker pathway for the 2027 plan year. Authorization applies per plan year, agent, and EDE platform. A member whose coverage renews automatically without an agent taking action is not the same as a member whose agent actively handles an application or enrollment.
Can an agent make a plan change without a three-way call in 2027?
CMS is sunsetting the July 2024 InvalidAction error and three-way-call workaround for Open Enrollment 2027. An agent may make certain changes directly through the EDE platform after required identity proofing and authorization. The separate consent and application-review requirements still apply.
What should a consumer do if an authorization request is unexpected?
Do not approve it or share a passcode. Check the agent’s name and NPN, contact the intended agent using independently obtained contact information, and confirm the application and platform. If the request appears unauthorized, check the Marketplace account and contact the Marketplace Call Center.
VerifiedAgent provides a searchable directory of insurance agent profiles and recorded customer reviews. Use the state directory to begin an agent search, then independently confirm current licensing and authorization before proceeding.
