CMS just released new guidance outlining changes to agent-driven applications that will begin on October 12, 2026.

We're sharing the key updates, what they mean for agents, and how you can prepare ahead of Open Enrollment.

1. Broker-assisted enrollments and changes will no longer be possible via the Marketplace call center

Beginning on October 12, 2026, all consumers will need to authorize you as their agent before you can access, update, or submit their Marketplace application. With this new agent authorization step, you will be able to use HealthSherpa for all agent-assisted enrollments and application updates. 

For Open Enrollment 2027 and beyond, CMS is sunsetting the three-way call for AOR changes, and the Marketplace Call Center will no longer support enrollments or application updates with a broker’s NPN attached. 

HealthSherpa will make the agent authorization process as seamless as possible:

• You send the request. Send the consumer an authorization link by email or text.

• The consumer authorizes you. The consumer opens the link and completes a simple authorization step.

• You access the application. Once authorization is complete, you can begin assisting with the application in HealthSherpa. 
  
  

2. Review your consumer contact information now

Accurate consumer phone numbers and email addresses will be essential once authorization goes live. This is how consumers will receive and complete their authorization requests. Starting now is the best way to avoid delays during Open Enrollment.

Here's what happens if a consumer's contact info on file is outdated or invalid after this change goes live:

• The consumer can update their own contact information by calling the Marketplace Call Center directly. This must be done by the consumer themselves, without the agent on the line.

   

• Alternatively, the consumer can submit an application with their correct information directly through HealthCare.gov or another consumer-driven pathway.

   

3. Agent authorization stays with the EDE platform

Authorization completed through HealthSherpa is valid only on HealthSherpa and does not transfer to another EDE platform. The authorization remains active for the plan year while you continue assisting the consumer through HealthSherpa.

If you move the consumer to a different EDE platform, the consumer will need to complete that platform’s authorization process using a new and different workflow. 

4. Some consumers will need identity verification

CMS may require additional identity verification for certain higher-risk applications. A consumer may be asked to verify their identity when:

• They submit a new Marketplace application, including an application in a different state

• They have an active Marketplace enrollment with a monthly premium of $30 or less after APTC

• They begin working with a new or different agent or broker

HealthSherpa’s identity verification experience will include multiple approved options, including the CMS-provided Experian Remote Identity Proofing process (RIDP), which happens in the background without impact to the user, ID.me, and other available methods. 

Our goal is to help more of your consumers successfully complete identity verification without needing to complete the enrollment on their own using

HealthCare.gov.    

5. Consent documentation is still required 

Agent authorization provides access to the application. It does not replace CMS' consent documentation requirements. Agents will still be required to obtain and document consent from their consumers. This includes

• Consent documentation before person search

• Application review and consumer attestation

• Any other applicable CMS documentation requirements