CMS tells agents to prepare for ACA open enrollment

The Centers for Medicare and Medicaid Services told agents about pre-enrollment verification requirements. (AI-generated image)

By Susan Rupe

WASHINGTON, D.C. - The 2028 open enrollment season for Affordable Care Act health plans is more than a year away. However, agents and brokers need to complete some preparation before they can begin signing clients up for 2028 coverage.

The Centers for Medicare and Medicaid Services is implementing pre-enrollment verification for consumers who qualify for tax subsidies to pay for their premiums.

This means that, before a consumer can enroll with a premium tax credit, they must be determined to be eligible, Dean Mohs, director of CMS’ Division of Strategic Stakeholder Engagement Operations, said during the Health Agents for America 2026 Agent Summit.

“One thing you can do this year to get ready is try to reach as many of your customers as possible,” Mohs said to the agents. “Know where they live and how to get in touch with them.”

A proposed rule on pre-enrollment verification will be published in the coming months, Peter Nelson, deputy administrator and director of the Center for Consumer Information and Insurance Oversight, told HAFA attendees. Until then, agents were advised to check in regularly with clients who receive tax credits.

Combatting fraud, waste and abuse in the ACA marketplace remains one of CMS’ top priorities, Mohs said.

“We can’t combat fraud without your help,” he said. “Fraud in this space doesn’t just impact consumers who were enrolled in a plan without their knowledge or had their plan switched without their knowledge; it impacts brokers who are playing by the rules and doing what they can to help their customers every day.”

Changes to ACA enrollment

Consumer identity proofing will be implemented this year for the ACA marketplace, Mohs said. In addition, CMS is moving toward a system where a broker is explicitly linked to a consumer's ACA marketplace application through agent/broker authorization and identity-proofing controls, especially when enrollment occurs through Enhanced Direct Enrollment platforms.

Historically, a consumer could be associated with an agent through a National Producer Number, but CMS has been tightening controls over how NPNs are attached to applications. CMS has indicated that agents should use approved EDE pathways and authorization processes rather than directly modifying application records.

CMS's August 2026 FAQ explains that EDE platforms historically varied in how they handled identity verification and authorization. CMS said those gaps created opportunities for unauthorized enrollments and unauthorized plan switches.

“You have been asking us to do something to connect the system to a broker,” Mohs said. “It’s a start, and over time we will improve it and make it stronger.”

Prepare for open enrollment

Mohs called on agents to “do what you do every year as you prepare for open enrollment- provide consumers with the best experience possible. You do it in several key ways: When you help consumers estimate their income, be as precise as you can with income estimates, and work with your customers to resolve data-match issues as soon as you can.”

Mohs said more than 100,000 brokers registered with CMS for the most recent ACA open enrollment period, and 75% of marketplace enrollments came from brokers during that period. That represents nearly 2 million new enrollees and 6.3 million renewals that came in through brokers.

Susan Rupe is editor in chief, magazine, for InsuranceNewsNet. She formerly served as communications director for an insurance agents' association and was an award-winning newspaper reporter and editor. Contact her at susan.rupe@innfeedback.com.