2027 Health Care Changes

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 This CMS notice explains major new security requirements for Marketplace agents and brokers using Enhanced Direct Enrollment (EDE) platforms. The requirements must be implemented by EDE platforms no later than October 12, 2026, ahead of the 2027 Open Enrollment Period.

Agents will no longer be able to complete an application, enrollment, plan change, or certain document uploads until the consumer completes the required identity verification and authorizes that specific agent.

Applications will be classified as either high-risk or low-risk.

High-risk applications include:

• New Marketplace applications
• Consumers applying in a different coverage state
• Existing enrollments with a net premium of $30 or less per month
• Consumers working with a new or different agent

For high-risk cases, the consumer must generally:

1. Pass identity verification.
2. Authorize the agent.
3. Complete both steps before the agent can continue.

Low-risk cases generally require only agent authorization through a one-time passcode, confirmation link, or similar method.

The EDE platform may contact the consumer by text, email, or automated telephone call.

• Passcodes and links will be single-use.
• They must expire within 15 minutes.
• No more than three notifications may be sent within 24 hours for the same agent/application combination.
• If the consumer fails identity verification, the agent will be blocked from proceeding.
• The consumer may need to contact Experian or complete verification through HealthCare.gov.

• Every consumer must provide an email address and telephone number they can personally access.
• Agents cannot use their own email address, phone number, mailing address, company contact information, or dummy information on a consumer’s application.
• Existing clients with outdated information may need to update it themselves through the Marketplace Call Center or submit an application through a consumer pathway.
• Marketplace consent documentation is still required. The new electronic authorization does not replace the existing consumer-consent requirement.
• Consent must be obtained and documented before searching for or accessing the consumer’s Marketplace application.

• Identity verification may remain valid indefinitely on a particular EDE platform if the consumer has an account and the verification is tied to it.
• Without an account, identity verification must generally be completed again each coverage year.
• Agent authorization will generally be required every plan year.
• Authorization lasts for that plan year unless the consumer authorizes a different agent.

An agent must be authorized before uploading documents for:

• Data Matching Issues
• Special Enrollment Period verification issues

Only one agent user ID may be associated with an application at a time.

For 2027 Open Enrollment:

• CMS plans to eliminate the “InvalidAction” error that currently prevents a new agent from changing an existing enrollment.
• The three-way Marketplace call previously required for many agent-of-record or plan-change situations will generally be replaced by consumer identity verification and electronic agent authorization.
• The Marketplace Call Center will no longer make application or enrollment changes requested by agents.
• Agents will instead complete those activities through the EDE platform after the consumer verifies their identity and authorizes the agent.