New Rules at the Point of Enrollment — Effective for OEP 2027

Updated 2026-10-29

CMS’s Enhanced Direct Enrollment requirements add consumer identity-proofing and agent-authorization checks ahead of the 2027 open enrollment period. The agency’s August 3 FAQ set October 12, 2026, as the latest implementation date for EDE partner platforms.

The guidance applies to applications and enrollments submitted through the agent or broker pathway on EDE platforms serving the federally facilitated Exchange system, including state-based Exchanges on the federal platform. It should not be described as an identical workflow across every state Marketplace or every method of enrollment.

Every application requires authorization from the consumer before the agent can proceed. Higher-risk cases also require the household contact or application filer to complete identity proofing first. CMS identifies new applications, a move to a different coverage state, a change of agent, and existing active medical enrollments with a net monthly premium of $30 or less as high-risk situations. Stand-alone dental enrollment is excluded from that premium test.

Lower-risk cases still require a lightweight authorization step, such as a one-time code or confirmation link. Platforms may contact consumers by text, email, or automated phone call. Single-use links or codes must expire within 15 minutes, and the guidance limits notifications for a given agent-user and application combination to three within 24 hours.

Authorization does not replace the existing obligation to obtain and document consumer consent before searching for or accessing a consumer’s information. Agents must use contact information controlled by the consumer or an authorized representative—not the agent’s own email, phone number, or a dummy account.

Authorization is gathered for each plan year and can change when the consumer selects a new agent. Identity-proofing results may remain valid on a particular platform when tied to a consumer account; without that account, identity proofing must be reconfirmed for each coverage year. Do not assume a successful check automatically transfers to another platform.

Agent Takeaway: Confirm the consumer can receive messages, explain the verification step before the enrollment appointment, and learn the platform’s recovery process for failed identity proofing. The agent cannot bypass an incomplete check.

CMS also describes changes to prior plan-switching blocks and Marketplace Call Center workflows. Review the FAQ and your EDE partner’s operational instructions rather than rely on last year’s three-way-call process.