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Beginning October 12, 2026, the Centers for Medicare & Medicaid Services (CMS) will require all agent-driven Affordable Care Act (ACA) enrollments to include an agent authorization step.
Pending CMS approval, HealthSherpa will allow agents to begin the authorization process early so that agent's can get ahead of the Open Enrollment Period (OEP) for plan year 2027.
In this article we'll cover:
Review CMS' guidance and FAQs released August 7th, 2026 to learn more.
Agent authorization at a glance
Agent authorization is a consumer's confirmation that a specific agent is permitted to access or make changes to their Marketplace application. Beginning October 12, 2026, CMS will require this authorization for all agent-driven enrollments.
How the process works:
The agent sends a consumer an authorization request. For example, by texting or emailing a link.
The consumer reviews the request and confirms they want to grant authorization.
Before authorization can be granted, CMS may require identity verification for certain higher-risk applications.
Authorization is completed.
Authorization is required once per plan year, per agent, per Enhanced Direct Enrollment (EDE) platform. It is not required each time an agent interacts with the consumer's application.
How agent authorization, consent, and CMS' Invalid Action error differ
Agent authorization, CMS consent requirements, and CMS' Invalid Action error are three separate things.
Agents will need agent authorization to access or make changes to a consumer's Marketplace application if they do not already have authorization established for the plan year. Agent authorization does not meet CMS consent requirements or replace the need to capture consent.
Agents will still need to obtain and document consumer consent & eligibility application review when providing assistance.
CMS' Invalid Action error is based on the National Producer Number (NPN) currently associated with the enrollment. CMS will sunset the Invalid Action error beginning OEP for plan year 2027, however the two processes work differently:
CMS' Invalid Action error occurs at the end of an application and is based on NPN currently associated with the enrollment.
Agent authorization takes place before an agent can begin, access, or make changes to an application. It does not rely on NPN, and has no impact on the NPN associated with a consumer's existing enrollment.
Frequently asked questions
What can agents do to prepare for agent authorization?
Agents can prepare for agent authorization by confirming that all information listed on a consumer's plan year 2026 application is accurate and up to date.
Plan year 2027 authorization requests can be sent by email or text to the contact information associated with the consumer's application.
What if a consumer's contact information no longer matches what is listed on their application?
If a consumer's phone number or email address no longer matches the contact information listed on their application, or they no longer have access to the contact information listed on their application:
Plan year 2026: With consent, edit the consumer's application, then resubmit the application.
Plan year 2027: Consumers will need to submit their own enrollment using a consumer-driven pathway such as using an agent's marketing link, or calling the Marketplace directly at 1-800-318-2596.
Does authorization need to be repeated for every consumer each year?
Yes. Authorization is completed once per plan year, per agent, per Enhanced Direct Enrollment (EDE) platform.
What is an Enhanced Direct Enrollment (EDE) platform?
Enhanced Direct Enrollment (EDE) is a CMS-approved technology that creates a secure backend connection to the Marketplace. An EDE platform is an enrollment platform approved to use that connection, which allows agents to complete the full Marketplace enrollment process directly on the platform rather than on HealthCare.gov. HealthSherpa is an EDE platform.
Does authorization transfer to other EDE platforms?
No. Authorization is specific to the EDE platform where it is completed, so authorization completed through HealthSherpa is valid only through HealthSherpa and does not transfer to other EDE platforms.
If a consumer is moved to a different EDE platform, the consumer will need to complete that platform's authorization process.
How does CMS determine whether an application is high risk?
Before authorization can be granted, CMS may require additional identity verification for certain higher-risk applications. Applications flagged as high risk by CMS include:
New to the Marketplace or state
Enrollment is already active
Consumer is working with a different agent
Net monthly premium of $30 or less
Identity verification could also be required if an application moves from low risk to high risk during the enrollment journey.
How do consumers verify their identity when required?
Several identity verification pathways are available on HealthSherpa.
Identity verification for consumers will take place in the background using Experian. If a consumer’s application is flagged as high risk, and the consumer’s identity cannot be verified by Experian, HealthSherpa presents alternative verification pathways.
Consumers who have verified their identity in the past using HealthSherpa will not need to repeat this step annually.
What does net premium mean?
Net premium is the premium amount a consumer pays after advance premium tax credit (APTC) has been applied. In contrast, gross premium is the full premium amount before APTC is applied.
Does agent authorization affect commissions or Agent of Record (AOR) status?
No. Agent authorization concerns access to a consumer's application on HealthSherpa. Agent authorization does not affect the AOR associated with the enrollment, the National Producer Number (NPN) associated with the enrollment, or carrier commission relationships.
Does agent authorization impact applications done using an agent's marketing link?
No. Applications done using an agent's marketing link are consumer-driven enrollments. Agent authorization applies to agent-driven enrollments.
Can another agent, or agency administrator send an authorization request on behalf of an agent?
No. Authorization requests can only be sent by the agent requesting authorization.
Can agents still complete enrollment submissions by contacting the Marketplace Call Center?
Beginning OEP for plan year 2027, no. The Marketplace Call Center will no longer support enrollments or application updates with a broker’s NPN attached. For more information from CMS, review question 11 here.
Does this impact NPN override?
No. National Producer Number (NPN) override functionality will still be available within HealthSherpa.
Additional resources
For help using HealthSherpa or for other assistance, contact Agent Support. Agent Support is available by phone at (888) 684-1373, by email at Support@HealthSherpa.com, or by chat directly from your account.