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On July 19, 2024, the Centers for Medicare & Medicaid Services (CMS) implemented changes that block agents and brokers from making updates to a consumer’s Federally Facilitated Marketplace (FFM) enrollment unless the agent is already associated with the consumer’s enrollment. This applies to agent-assisted enrollment submissions across all enrollment platforms.
In this article we’ll cover:
CMS' Invalid Action error at a glance
CMS’ Invalid Action error may appear when an agent attempts to submit an update to an active Federally Facilitated Marketplace (FFM) enrollment and the agent’s National Producer Number (NPN) is not already associated with the consumer’s active policy.
CMS implemented this error to help prevent unauthorized agent activity and protect consumers from unauthorized changes to their Marketplace coverage.
When CMS’ Invalid Action error appears, agents should not create a new application to avoid the error. CMS may cancel applications they determine are duplicative.
Applications not impacted by the CMS Invalid Action error include:
Resubmissions by the same NPN
Resubmissions within an agency that uses NPN override when the Override NPN is not changing
Resubmissions started by an agent when the final submission is completed by the consumer, such as through HealthSherpa’s Resume Link
Submissions when the consumer does not have active coverage
New enrollments for a plan year
Agents can still help consumers complete enrollment submissions when CMS’ Invalid Action error appears by sending an agent’s Invalid Action error Resume Link or completing a 3-way call with the Marketplace Call Center.
The full statement from CMS about this change is available here.
Completing enrollment submissions when CMS’ Invalid Action error appears
When CMS’ Invalid Action error appears, agents can send the consumer an Invalid Action error Resume Link or call the Marketplace Call Center with the consumer on the line.
Send the consumer an Invalid Action error Resume Link
Send the consumer an Invalid Action error Resume Link
An agent’s Invalid Action error Resume Link lets the consumer review and submit the in-progress application from their own device.
From the CMS Invalid Action error page, choose whether to email, text, or email & text the Resume Link.
Let the consumer know they will need to verify their identity before submitting the application.
Ask the consumer to open the Resume Link from their own device, such as a phone, tablet, or computer. Review the consumer experience when using a Resume Link to learn more.
Call the Marketplace Call Center
Call the Marketplace Call Center
Agents can also call the Marketplace Call Center at 1-855-788-6275 with the consumer on the line for a 3-way call.
During the call:
The agent should tell the Marketplace Call Center representative that the consumer is on the line.
The consumer should tell the Marketplace Call Center representative they want to update the National Producer Number (NPN) associated with their policy.
The Marketplace Call Center representative can help update the consumer’s coverage.
Both options are designed to involve the consumer in the submission process. When an agent is attempting to submit enrollment updates on the consumer’s behalf, the consumer must review and approve the updates before the enrollment submission can be completed.
Identifying consumers with current plan year enrollments
HealthSherpa helps agents identify consumers who have current plan year enrollments.
When agents search & claim a Marketplace application, HealthSherpa may display an alert when a consumer already has a current plan year enrollment that is at risk of generating CMS’ Invalid Action error.
This alert may also appear on the consumer’s Details page.
Consumer experience when using a Resume Link
Consumers can choose to receive an agent’s Invalid Action error Resume Link from HealthSherpa by email or text.
The consumer will open the Resume Link from their own device, such as a phone, tablet, or computer. Review the consumer experience when using a Resume Link to learn more.
Tracking and reporting
Using the Invalid Action error tab on the Clients page, agents can track the progress of consumers who are using the agent's Invalid Action error Resume Link.
Columns & statuses
Columns & statuses
Client: The primary applicant’s name.
AOR: Name and National Producer Number (NPN) of the agent associated with the application, as reported by CMS.
Error seen: The date CMS’ Invalid Action error occurred and the plan year associated with the application.
Last synced: The most recent date data was synced between the Marketplace application and the HealthSherpa account.
Status: The status of the CMS Invalid Action error. Statuses include:
Action required: The consumer likely needs agent outreach to clarify next steps.
Action recommended: The consumer may benefit from agent outreach to clarify next steps.
3-way call detected: A 3-way call with the Marketplace Call Center may have been completed.
Completed: The enrollment submission is complete.
Details: More information about where the consumer is in the Invalid Action error Resume Link process.
Action: Includes options to view the consumer's record or resend the Resume Link.
Agents and agencies can also export Invalid Action error data.
Frequently asked questions
Does the CMS Invalid Action error impact applications done using an agent's marketing link?
No. Applications done using an agent's marketing link are consumer driven enrollments. The CMS Invalid Action error applies to agent driven enrollments.
What happens if an agent tries to resubmit an application that was previously submitted without an NPN attached?
CMS’ Invalid Action error will appear when trying to add a National Producer Number (NPN) to the policy.
Which NPN does CMS use when determining whether to block a resubmission?
CMS looks at the latest NPN tied to the consumer’s active policy.
Can any agent who was previously associated with an application complete an enrollment update?
If an agent with consent needs to update an application for a consumer who has an active policy, the agent may do so if the NPN on the consumer’s policy will not change. If the NPN will change, the agent will encounter CMS’ Invalid Action error.
How does NPN override work with resubmissions?
Agencies that use NPN override can follow these steps to ensure the desired Override NPN is associated with a resubmission:
With consumer consent, complete the updates to the application through the plan confirmation page.
Select the desired Override NPN on the plan confirmation page.
After submitting the application and receiving CMS’ Invalid Action error, share the Resume Link with the consumer.
The desired Override NPN will be associated with the Resume Link when the consumer completes the application.
Who can assist a consumer with canceling an application?
Only the original Federally Facilitated Marketplace (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, an error message will appear.
Do Resume Links expire?
Yes. Resume Links typically expire after 30 days.
Why does an error message appear when attempting to text the Resume Link?
An error message may appear when trying to text a CMS Invalid Action error Resume Link for several reasons. Examples include:
The maximum number of text attempts allowed within a 24-hour period has been reached.
The phone number entered cannot receive texts.
The phone number has returned as undeliverable, such as a number listed on a do not call list.
What if the consumer's identity cannot be verified?
If a consumer experiences any issues verifying their identity, troubleshooting steps are available.
If an agent sends a Resume Link, does the agent still need to document Eligibility Application Review?
Yes. Agents are still required to follow all CMS consent requirements when assisting consumers.
What does it look like when the Resume Link is successfully sent?
When a Resume Link is successfully sent to a consumer from HealthSherpa, a success alert like this will display:
Can consumers access their Resume Links from my office?
Yes; however, the consumer's identity is automatically verified by CMS' partner, Experian, during the submission process. Because of this, consumers will need to use their own personal devices (phone, tablet, or computer) when completing their Resume Link submissions.
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 should agents do if they experience issues during a 3-way call with the Marketplace Call Center?
Agents who experience issues during a 3-way call with the Marketplace Call Center should report the call. Examples of issues include:
Misinformation is provided.
The representative questions the plan selection.
The representative does not process the request as expected.
Agents should report these calls to the Federally Facilitated Marketplace (FFM) Agent/Broker Help Desk and to HealthSherpa’s Agent Support team. Information needed to report a call includes:
Date and time of call
Application ID
Consumer’s state
Phone number of the person who placed the call
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.
What happens if CMS’ Invalid Action error appears during an Enrollee Assistance Program enrollment?
Enrollee Assistance Program (EAP) enrollments may only be processed using the HealthSherpa platform.
If CMS’ Invalid Action error appears during an EAP enrollment, the enrollment must be submitted by the consumer using the Invalid Action error Resume Link pathway in order for the enrollment to be eligible for EAP compensation. It is not possible to process an EAP enrollment using a 3-way call with the Marketplace Call Center.
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 Agent_Support@HealthSherpa.com, or by chat directly from your account.
To submit feedback or ask questions about CMS' Invalid Action error, reach out to the Marketplace Call Center at 1-855-788-6275. CMS resources:
FFM agent/broker help desk FFMProducer-AssisterHelpDesk@cms.hhs.gov
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