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The Federally Facilitated Marketplace (FFM) will only accept applications submitted by agents that include verifiable SSNs for all applicants over 90 days old. Agents assisting non-U.S. citizens who do not have an SSN but do have qualifying immigration status will be able to enter immigration document details instead. This applies to agent assisted applications submitted on all enrollment platforms.

All SSNs and immigration documentation entered will be verified in real time. If the applicant does not have a verifiable SSN or immigration documentation, the SSN or immigration documentation provided is deemed invalid, or the SSN or immigration documentation provided does not match the information of the applicant, the agent-driven application will not be allowed to move forward. SSN and immigration documentation review is entirely handled on the CMS side and specific errors will display on HealthSherpa for Agents depending on their findings.

Consumers who do not wish to provide their SSN or immigration documentation at the time of application can submit their own application or agents can continue assisting these consumers with their enrollment by calling the Marketplace Call Center.

CMS Resources:

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 applying for coverage, select the ‘Yes’ radio button when answering the “Are you applying for coverage” question. If this radio button is set to ‘Yes,’, the Primary contact will become the Primary applicant.

If the Primary contact is not applying for coverage (i.e. child-only plans), you may select the ‘No’ radio button when answering the “Are you applying for coverage” question.

When entering the primary applicant's information within the 'Primary contact' section of the application, SSN is a required field for U.S. citizens who have been issued an SSN. When assisting non-U.S. citizens without an SSN, you may select the ‘I don’t have a SSN’ checkbox to proceed. Selecting the ‘I don’t have a SSN’ checkbox will generate a reminder informing you that immigration documentation will be required on the following pages.

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 the Primary contact is not applying for coverage, entering an SSN is optional.

Note: If the Primary contact is not applying for coverage, providing an SSN here is still recommended in order to speed up the application process for those who are seeking coverage.

If the ‘I do not have a SSN’ checkbox is selected for the primary applicant, and later it is noted within the ‘Members’ section that the consumer is a U.S. citizen, a ‘SSN Required’ message will appear informing you that you may not proceed without an SSN for the primary applicant:

If the ‘I do not have a SSN’ checkbox is selected for the primary applicant, and the consumer is a non-U.S. citizen, immigration documentation information will be required within the ‘Members’ section in order to proceed:

When adding additional applicants to the application within the 'Household' section, SSN is a required field for U.S. citizens who have been issued an SSN. When assisting non-U.S. citizens without an SSN, you may select the ‘This person doesn’t have an SSN’ checkbox to proceed. Selecting the ‘This person doesn’t have an SSN’ checkbox will generate an alert reminding you that immigration documentation will be required on the following pages.

Agents assisting with enrollments for applicants under 90 days old who have not yet have an SSN will be able to select a 'This person doesn't have an SSN’ checkbox. 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 neither the SSN is provided or the ‘This person doesn’t have an SSN’ checkbox is selected, an error message will appear informing you that you may not proceed without entering this data for each applicant.

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

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

CMS will verify each SSN and set of immigration documentation details entered on an application. Possible verification error messages that may display during the application process include:

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:

If the SSA deems an applicant’s documentation information entered on the application is unverifiable, you will see an 'Immigration details couldn’t be verified' error message within the verification required screen.

The error message informs you that consumers without verifiable immigration documentation 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:

Upon receiving an 'Immigration details couldn't be verified' 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.

CMS will verify SSNs and immigration documentation details 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 error.

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.