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As of July 19, 2024, CMS is blocking agents and brokers from making changes to a consumer’s FFM enrollment unless the agent is already associated with the consumer’s enrollment. This applies to all agent-assisted enrollment applications across all enrollment platforms.
For more information on the changes CMS has implemented, access the full statement from CMS here.
In this article we will cover:
You can also watch a recording of this webinar here.
Error message from CMS
What this means for agents: When an agent submits an update to an enrollment that their NPN is not already associated with, that agent will see the following "Invalid Action" error from CMS:
Agents will also see an alert when searching applications that are at risk of generating this CMS error as well as within the client’s details page.
How to submit policy changes when encountering this error
Do not create new applications for consumers in an attempt to avoid this error. CMS, at its own discretion, may cancel applications they see as duplicative.
If you encounter this new error, you may assist the consumer in submitting the changes themselves or you can complete the consumer’s enrollment by calling the Marketplace Call Center.
Have the consumer submit the changes themselves: You can help a consumer complete their own application change by doing the following:
Assist the consumer to make policy updates as you normally would.
When you encounter the new CMS error, send the consumer their in-progress application. You may send the in-progress application by emailing the Resume Link directly from the error page or choose to copy the link to share it another way. You will not see the ‘Email resume link’ option for clients without an email already included on their application:
The consumer will be required to have their identity verified in order to proceed. See ‘Consumer experience when using a Resume Link’ for next steps; you may also share these steps with your consumer to help them complete their submission. If the consumer receives an ‘Unable to verify your identity’ alert during the identity proofing process, they will not be able to proceed. If the consumer is unable to verify their identity, you will need to call the Marketplace Call Center at 1-855-788-6275 with the consumer on the line for a 3-way call and ask a representative to update the consumer’s coverage.
Call the Marketplace Call Center after you have encountered the error: After you receive the error, call the Marketplace Call Center at 1-855-788-6275 with the consumer on the line for a 3-way call and ask a representative to update the consumer’s coverage.
Agents should advise the Marketplace Call Center representative that the consumer is on the line
The consumer should advise the Marketplace Call Center representative that they want to update the NPN associated with their policy
Learn more about the consumer’s experience when using a Resume Link here.
Identifying consumers with current plan year enrollments
HealthSherpa has rolled out functionality to help Agents identify clients who have current plan year enrollments. When searching for a consumer using our Marketplace search and claim functionality, we will display a banner informing you when a consumer already has a current plan year submission. The banner will also appear on the Client’s details page:
The Consumer’s experience when using a Resume Link
Consumers may be sent a Resume Link directly from HealthSherpa or they may be sent a Resume Link via email. Learn more about the consumer's experience when using a Resume Link here.
Frequently asked questions
Does the CMS error impact all applications?
No. Non-impacted applications include:
Re-submissions by the same NPN
Re-submissions within an agency that uses NPN Override where the Override NPN is not changing
Re-submissions started by an agent where the final submission is done by the consumer (e.g. via HealthSherpa’s Resume Link)
Submissions when the consumer does not have active coverage
New enrollments for a plan year. Note: Do not create new applications for consumers in an attempt to avoid this error. CMS, at its own discretion, may cancel applications they see as duplicative.
Can I create a new application for customers instead of updating an existing application?
No. Duplicating applications puts many consumers at risk of losing coverage and CMS is tracking duplicate applications.
CMS, at its own discretion, cancels applications they see as duplicative. Agents and consumers will not be immediately made aware of CMS cancellations that occur due to duplication; although the consumer will be notified by the issuer at a later time. To avoid this scenario for you and your consumers, please use an alternative method of completing the original application.
What happens if an agent tries to re-submit an application that was previously submitted without an NPN attached?
The CMS error message will be triggered when trying to add an NPN to the policy.
Which NPN is CMS looking at when determining when to block re-submissions?
CMS is looking at the latest NPN tied to a consumer’s active policy. If an agent assists a consumer with inactive coverage, the error message should not generate.
Can any agent that was previously associated with an application complete an enrollment update? For example, if there have been 8 different agents associated with a consumer’s 2024 application, are all 8 agents still able to update an enrollment without hitting the CMS error?
If an agent with consent needs to update an application for a consumer who has an active policy, they may do so if the NPN on the consumer’s policy will not be changed by the update. If the NPN will be changed by the update, the agent will hit the CMS error and use an alternative method of completing the original application.
I am part of an agency that uses NPN override. How do I ensure the correct NPN gets associated with the re-submission?
Here are the steps agents should take to ensure a desired Override NPN is associated with a re-submission:
With customer consent, complete the updates to their application through the plan confirmation page
Select the desired Override NPN on the plan confirmation page
After submitting the application and receiving the error message, share the Resume Link with your consumer
The desired Override NPN will be associated with the Resume Link when the consumer completes the application
Who can assist a customer with canceling an application?
Only the original FFM username associated with the active policy may assist a consumer with canceling an application. If a different FFM username than the original FFM username associated with the active policy attempts to cancel an application from within HealthSherpa, the following error message will appear.
Do Resume Links expire?
No. The Resume Link does not expire.
Can I text the Resume Link to my client?
We do not currently support the ability to automatically text the Resume Link to your customer from HealthSherpa directly; however, Agents can share the link through any channel desired (e.g. text) once they copy the link. Learn more about the consumer's experience when using a Resume Link here.
What does it look like when I've successfully sent or copied the Resume Link?
When you've successfully sent or copied the Resume Link, you will receive success alerts such as those pictured below.
Can consumers access their Resume Links from my office?
While technically possible, you'll want to work with the consumer to determine their comfort level with this. Since identity verification is required, many consumers may wish to do this privately or by using a private internet connection.
All resume link submissions must be completed by the consumer.
What if my consumer cannot complete the new verification steps?
If verification or ID-proofing is not successful, call the Marketplace Call Center at 1-855-788-6275 with the consumer on the line for a 3-way call and ask a representative to update the consumer’s coverage.
If I sent my consumer the Resume Link, do I still have to document Eligibility Application Review (consent)?
Yes. Agents will have the opportunity to collect Eligibility Application Review within the Confirm plan screen and are still required to follow all CMS requirements surrounding consent when assisting consumers. Learn more here.
What if I experience issues when conducting a 3-way call with the Marketplace Call Center?
Agents who experience problems while conducting a 3-way call with the Marketplace Call Center (misinformation is provided, the representative questions the plan selection, etc.) should report the call.
Agents should report these calls to the FFM agent/broker helpdesk (FFMProducer-AssisterHelpDesk@cms.hhs.gov, CMS resource: Tips for agents and brokers when using the Marketplace call center) and also to HealthSherpa’s Agent Support team.
Information needed to report a call includes:
Date and time of call
App ID
Consumer’s state
Phone number of person who placed the call
A summary of the issue
Is the primary contact the only person able to approve updates to an existing application?
Yes. Only the primary contact may approve updates to an existing application.
Is the primary contact the same as the primary applicant?
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.
Is it still possible to email a Resume Link to consumers from the Client list?
No. The Resume Link may only be shared with consumers from the Invalid Action error page.
Why do consumers have to create an account?
CMS regulations include consumer identify verification and that consumers create a proper account on that EDE platform.
How do I explain who HealthSherpa is to my consumer?
Consider an answer like:
HealthSherpa is a website I use to help my clients find affordable health coverage through HealthCare.gov. They're really secure and work to protect customers against fraud, so they require you to log in and verify the choices and changes we've made together. The cool thing is, by creating an account, you'll not only be able to view your proposed application updates, but you'll also be able to view your plan information, make your first premium payment, access any notices sent from HC.gov during the year, and even view the 1095-A form that you'll need once it's tax time!
Additional Resources
To submit feedback or ask questions about these changes from CMS, reach out to the Marketplace Call Center at 1-855-788-6275. CMS resource: Tips for agents and brokers when using the Marketplace call center.
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.
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