UPDATE: CMS - Verified SSN/Immigration Documentation Required for 2027 Re-Enrollment
Health/ACA agents and brokers who assist consumers enrolling through HealthCare.gov, particularly those with 2026 Marketplace clients who will be re-enrolled for 2027.
What Agents Need to Know
CMS is adding a verification step to the 2027 Marketplace auto-re-enrollment process to enforce the existing requirement for a verified Social Security number (SSN) or immigration documentation for each applicable applicant.
If an application does not meet this requirement, CMS may automatically re-enroll the consumer for 2027 but remove the agent’s National Producer Number (NPN) from the enrollment, potentially affecting commission payments.
Action Required Before December 15, 2026
To help protect commissions on eligible enrollments, agents should review their clients’ 2026 Marketplace applications and ensure each applicable applicant has the required verified documentation.
Review existing applications: Confirm the required verified SSN or immigration documentation is included for each applicable applicant.
Update missing information: Work with consumers to correct incomplete applications before Open Enrollment.
Confirm active re-enrollment: If a consumer updates their 2027 application and actively re-enrolls by December 15, 2026, CMS states the NPN will not be removed under this process.
Important Reminders
A verified SSN is required for applicants over 90 days old. If a non-citizen applicant does not provide an SSN, verified immigration document information must be provided for the application to proceed.
Agents and brokers must never create or log in to a consumer’s HealthCare.gov account or access the consumer’s login credentials.
When assisting consumers, agents and brokers should not identify themselves under Navigator, Certified Application Counselor, or Other Assister categories.
Questions or Support
For questions about this requirement, contact the CMS Agent/Broker Email Help Desk:
Source: Centers for Medicare & Medicaid Services (CMS), Verified SSN/Immigration for Re-Enrollment, September 25, 2026.
