As of October 6, 2024, CMS blocks agent-driven applications without verifiable Social Security Numbers (SSNs). The Federally Facilitated Marketplace (FFM) will only accept applications submitted by agents that include verifiable SSNs for all applicants over 90 days old. This applies to agent assisted applications submitted on all enrollment platforms.

All SSNs entered will be verified with the Social Security Administration (SSA) in real time. If the applicant does not have an SSN, the SSN provided is deemed invalid, or the SSN provided does not match the name and date of birth of the applicant, the agent-driven application will not be allowed to move forward. SSN review is entirely handled on the CMS side and specific errors will display on HealthSherpa for Agents depending on their findings.

Consumers without an SSN can apply for coverage by submitting their own application or agents can continue assisting the consumer with their enrollment by calling the Marketplace Call Center.

CMS Resources:

In December 2024, CMS plans to make additional updates to accept applications submitted by agents for noncitizen applicants who don't have SSNs but can provide verifiable immigration document information on the application

The Primary contact on a consumer's subsidy application is typically the primary tax-filer for the household or spouse of the primary tax-filer (if married and filing jointly). If the Primary contact listed is not applying for coverage (i.e. child-only plans), you may select the “I’m not applying for coverage” checkbox. If this checkbox is not selected, the Primary contact will become the Primary applicant.

When entering the primary applicant's information within the 'Primary contact' section of the application, SSN is now a required field and includes informative language dictated by CMS.

Note: Child-only applications are possible within HealthSherpa for Agents, but children cannot be listed as the primary contact on an application. The primary contact listed on a child-only application should be the person claiming the child within their tax household or the child’s guardian. Reach out to Agent Support if you need assistance completing a child-only application.

If an SSN is not entered for the primary applicant, a ‘Required’ message will appear informing you that you may not proceed without an SSN for the primary applicant:

Consumers without an SSN can apply for coverage by submitting their own application or agents can continue assisting consumers without an SSN with their enrollment by calling the Marketplace Call Center.

When adding additional applicant's to the application within the 'Household' section, SSN is now a required field for each individual and includes informative language dictated by CMS.

Checking the box 'Applicant doesn't have an SSN and is under 90 days old' will allow you to add infant applicants who do not yet have an SSN. Note: The date of birth field will be cross-checked if this check box is selected to ensure the applicant is under 90 days old.

If an SSN is not entered for additional applicants, an error message will appear informing you that you may not proceed without an SSN for each applicant. The error message informs you that consumers without an SSN can apply for coverage by submitting their own application or agents can continue assisting the consumer(s) with their enrollment by calling the Marketplace Call Center:

Should you need to adjust the status of a household member from non-applicant to applicant, an SSN will be required. When adding applicant's to the application, you will be taken to the 'Household' section to add an SSN for any new applicants.

Should you need to adjust the status of a household member from applicant to non-applicant, an SSN will be adjusted from required to optional for that individual within the 'Household' section.

CMS will verify each SSN entered on the application against information managed by the Social Security Administration (SSA). If the SSA deems an applicant’s information entered on the application does not match what is on file with the SSA or is unverifiable for any reason, you will see an 'Invalid SSN' screen at the conclusion of the 'Members' section of the application.

Possible error messages that may display within the 'Invalid SSN' screen include Social 'Security Number (SSN) required' & 'SSN couldn't be verified.'

If the SSA deems an applicant’s information entered on the application does not match what is on file with the SSA, you will see a 'Security Number (SSN) required' error message within the 'Invalid SSN' screen.

The 'Security Number (SSN) required' error occurs in situations such as the SSN holder having a different legal name than what was entered on the application or a typo was made when entering a consumer’s SSN.

To resolve the 'Security Number (SSN) required' error, you may:

Agents will have limited attempts to resolve the 'Security Number (SSN) required' error. These limits are set by the SSA. Should these attempt limits be reached, an 'SSN couldn't be verified' error message will appear informing you that you may not proceed without a verified SSN for each applicant. The error message informs you that consumers without a verifiable SSN can apply for coverage by submitting their own application or agents can continue assisting the consumer(s) with their enrollment by calling the Marketplace Call Center:

If the SSA deems an applicant’s information entered on the application is unverifiable with the SSA, you will see a 'SSN couldn't be verified' error message within the 'Invalid SSN' screen. The error message informs you that consumers without a verifiable SSN can apply for coverage by submitting their own application or agents can continue assisting the consumer(s) with their enrollment by calling the Marketplace Call Center:

The 'SSN couldn't be verified' error occurs in situations such as the SSN entered not belonging to a living individual.

Upon receiving an 'SSN couldn't be provided' error, you may:

CMS requires an SSN on the application for the primary applicant & anyone applying for coverage.

Entering an SSN is strongly recommended for any non-applicant household members as well because excluding their SSN will likely generate an Income related Data Matching Issue (DMI) that requires documents be uploaded to prove income. This is because CMS uses even non-applying tax household members' income to determine subsidy amounts. Learn more here.

If an income DMI is not resolved, consumers risk losing their subsidy eligibility which may lead to a terminated policy.

Sometimes. The Primary contact on a consumer's subsidy application is typically the primary tax-filer for the household or spouse of the primary tax-filer (if married and filing jointly). If the Primary contact is applying for coverage, the Primary contact is also the Primary applicant.

The primary contact listed on a child-only application is typically the person claiming the child within their tax household or the child’s guardian. This is because children cannot be listed as the primary contact on an application.

If you are having any technical issues using HealthSherpa, please contact our Agent Support team at (888) 684-1373, at agent_support@healthsherpa.com, or via chat from within your account.