ACA agents preparing for the 2027 Open Enrollment Period have an important new Marketplace requirement to add to their enrollment workflow.
Beginning October 12, 2026, CMS will require Enhanced Direct Enrollment (EDE) platforms to obtain consumer authorization for the specific agent or broker assisting with an application before that agent can proceed through the agent/broker enrollment pathway.
The change is designed to give consumers greater control over who can access and act on their Marketplace applications while helping CMS prevent unauthorized enrollments and plan changes.
For agents, the biggest takeaway is simple: consumer authorization will become a required step in the EDE enrollment process.
Agent Authorization is the consumer's confirmation that a specific agent or broker is permitted to access and work with their Marketplace application through an EDE platform.
Beginning October 12, agents may be blocked from proceeding with an application or enrollment through the EDE agent/broker pathway until the required authorization has been completed.
Depending on the EDE platform, consumers may receive an authorization request through methods such as:
CMS requires these authorization mechanisms to be single-use and expire within 15 minutes.
The exact workflow may vary by EDE platform, so agents should become familiar with the process used by their enrollment technology before OEP begins.
Agent authorization generally applies once per plan year, per agent, per EDE platform.
Once a consumer authorizes an agent, that authorization can remain in place for the plan year unless the consumer authorizes a different agent.
Only one agent authorization can be active at a time for an application. If the consumer authorizes another agent, the previous authorization is replaced.
Authorization also does not automatically transfer between EDE platforms. If an agent moves a consumer to another EDE platform, a new authorization may be required.
This distinction is especially important.
Agent Authorization, Consumer Consent, and Eligibility Application Review are separate requirements.
Agents must continue following existing CMS requirements for obtaining and documenting consumer consent before accessing consumer information or searching for a consumer on an EDE platform.
In other words, receiving the new Agent Authorization does not eliminate your existing consent documentation responsibilities.
Think of Agent Authorization as an additional Marketplace access control, not a replacement for your existing compliance process.
CMS is also implementing a risk-based identity-proofing process.
Certain applications classified as high risk may require the consumer to verify their identity before they can authorize an agent.
CMS identifies several situations that can trigger the higher-risk process, including:
For lower-risk applications, authorization may involve a simpler process such as a one-time passcode or confirmation link.
If identity verification is required and cannot be completed, the agent may be unable to proceed until the consumer successfully completes the required identity-proofing process.
This change makes accurate consumer contact information even more important.
Authorization and identity-verification requests may be delivered directly to the consumer using the phone number or email address associated with the application.
Agents should therefore make verifying consumer contact information part of their pre-enrollment preparation.
CMS also makes clear that agents must never substitute their own personal, professional, or agency contact information for the consumer's information. The consumer or authorized representative must have direct access to the email address and phone number entered on the application.
For returning clients, discovering an outdated phone number or email address during a busy enrollment appointment could create unnecessary delays.
Don't assume that because you helped a client last year—or because your NPN is already associated with their enrollment—you automatically have the authorization required for 2027.
Agent Authorization is separate from the NPN associated with an enrollment.
CMS states that authorizations should generally be collected each plan year. EDE partners may have options for handling agents already associated with existing applications when the new requirements are implemented, but agents should prepare for many existing clients to complete the authorization process for PY 2027.
This makes proactive client communication before OEP especially valuable.
There is also good news for agents.
CMS plans to sunset the InvalidAction error for OEP 2027 as the new identity-proofing and authorization requirements are implemented.
Previously, an agent who wasn't already associated with a consumer's enrollment could encounter a system block and potentially need additional steps, such as a three-way call with the Marketplace Call Center, to make certain enrollment changes.
The new authorization framework is intended to establish directly through the EDE pathway that the consumer has authorized the agent to act on their behalf.
CMS has also indicated that, beginning with OEP 2027, the Marketplace Call Center generally will no longer support application or enrollment changes requested by an agent because authorized agents will be able to complete those activities through the EDE agent/broker pathway.
Agents should use the remaining time before implementation to prepare their enrollment process.
Review your EDE platform's authorization workflow. The CMS requirements apply across EDE partners, but the user experience may differ by platform.
Verify client contact information early. Make sure returning clients have access to the phone number and email address associated with their Marketplace application.
Don't confuse authorization with consent. Continue collecting and documenting Consumer Consent and Eligibility Application Review as required.
Prepare clients for the extra step. Let clients know they may receive a text, email, passcode, or verification request during the enrollment process and may need to take action before you can continue.
Build additional time into appointments. Some consumers—particularly those requiring identity verification—may take longer to complete the process.
Train your staff. Agency owners, recruiters, marketers, administrative staff, and licensed agents should understand how the new process affects access to Marketplace applications.
HealthSherpa has confirmed that its platform will support the new Agent Authorization requirements beginning October 12, 2026.
According to HealthSherpa, authorization will be required once per plan year, per agent, per EDE platform. HealthSherpa also notes that authorization does not affect the Agent of Record, NPN associated with the enrollment, or carrier commission relationship.
Agents using HealthSherpa should review its implementation guidance closely as the platform finalizes its PY 2027 authorization workflows.
The new CMS Agent Authorization requirement adds another step to the ACA enrollment process, but agents who prepare now should be able to incorporate it into their existing workflow.
The key is understanding that authorization, consumer consent, and identity verification are related—but distinct—parts of the process.
Before October 12, review your enrollment platform's procedures, make sure your clients' contact information is accurate, and prepare your team to explain the new authorization step clearly to consumers.
A little preparation now can help prevent enrollment delays when OEP volume picks up.
CMS — EDE Identity Proofing and Agent/Broker Authorization FAQs
https://www.cms.gov/marketplace/agents-brokers/files/ede-identity-proofing-agent-broker-authorization-faqs.pdf
HealthSherpa — Agent Authorization Guide
https://faq.healthsherpa.com/en/articles/15693277-agent-authorization
This information is intended for insurance agent education and is not legal or compliance advice. Agents should review current CMS guidance and the requirements of their enrollment platform.