Starting with 2027 coverage, anyone who signs up for a Marketplace health plan through an agent or broker will have to supply a Social Security number or an immigration document number for every person on the application except a newborn. The Centers for Medicare & Medicaid Services announced the requirement as part of a wider crackdown on Marketplace enrollment fraud tied to agents and brokers. The rule reaches HealthCare.gov and the state exchanges that run on the federal platform, not marketplaces a state operates entirely on its own systems.
The requirement is one piece of a larger set of changes CMS rolled out together, and two of those pieces are easy to mix up. One is about the information an application must contain; the other is about who has to prove their own identity to CMS. They are not the same rule, and mixing them up is where most of the confusion has started. Someone who enrolls directly through HealthCare.gov, without an agent or broker involved at all, is not the audience for this particular requirement, since it is written to apply specifically to applications an agent or broker submits.
What CMS’s fact sheet requires of agent-assisted applications
In a September 22 fact sheet, CMS states that “all applications involving an agent or broker must include Social Security Numbers or immigration document numbers that CMS can verify for all non-newborn applicants.” That means every person listed on the application, aside from a baby born after enrollment, must have a verifiable number on file before the agent or broker can complete the submission. CMS frames the requirement as closing a gap where an application could previously go through without identifying information CMS could check, a gap the agency says agents and brokers used to add or change coverage for people who never authorized the change. The newborn exception exists because a newborn added to a family’s plan midyear typically has not yet been issued a Social Security number, so the fact sheet’s own carve-out reflects a practical limit rather than a loosening of the verification standard.
What the new SSN rule tries to prevent: CMS ties the requirement to enrollments an agent or broker changed without full authorization from the person on the plan, the same pattern behind many identity-theft cases. The family code word and fraud evidence log in The Senior Fraud Defense & First-Hour Recovery Kit support verifying a caller and documenting what happened if that occurs.
The identity check that applies to brokers, not applicants
A separate part of the same announcement has caused confusion. CMS says “all existing agents and brokers are now required to re-identity proof through either Login.gov or ID.me.” That re-verification step is a requirement placed on the agents and brokers who sell Marketplace plans for a living, not a new identity-proofing hurdle for the households who apply for coverage. Someone enrolling in a 2027 Marketplace plan through an agent will need to have a Social Security or immigration document number on file, but will not personally be asked to re-verify their identity through Login.gov or ID.me as part of this particular measure. A related regulation, the 2027 Notice of Benefit and Payment Parameters, finalized a companion piece of the same puzzle: agents, brokers and web-brokers must use an HHS-approved consumer-consent form to document that the person on the application actually authorized the agent to act on their behalf.
A registration freeze and hundreds of terminated agents
CMS also imposed what its fact sheet calls “a temporary moratorium on the registration of agents and brokers for 2027 who do not have an active Exchange Agreement for 2026,” meaning brokers new to the federal Marketplace cannot register to sell 2027 coverage. Since January 2026, the agency says it has sent termination notices to more than 200 non-compliant agents and brokers, on top of 569 notices of intent to terminate sent this summer to agents and brokers who had submitted 2026 applications missing applicant information such as Social Security numbers. An agent or broker who loses Marketplace access this way cannot simply re-register the following year without meeting the same identity and information standards the moratorium is built to enforce, which is part of why CMS describes the registration freeze and the termination notices as working together rather than as two separate programs.
How CMS frames the crackdown
CMS Administrator Dr. Mehmet Oz said in a related announcement that “every dollar lost to fraud is a dollar taken from hardworking taxpayers and the Americans these programs are intended to serve.” The identifying-number requirement, the broker re-verification rule and the registration moratorium are each pieces of that stated goal, aimed specifically at the channel, agent- and broker-submitted applications, where CMS says it has found the largest share of unverified information.
The identity risk this rule targets
CMS ties the new Social Security and immigration-number requirement to enrollments where an agent or broker put someone’s information on a Marketplace application without full authorization. Its fact sheet does not walk an individual household through what to do if it discovers an account, notice or enrollment it never authorized in the first place.
The Senior Fraud Defense & First-Hour Recovery Kit lays out the first-hour recovery plan and the free credit-freeze steps, alongside a fraud evidence and report log, for documenting an unauthorized enrollment or account change.
Read the first-hour recovery plan in The Senior Fraud Defense & First-Hour Recovery Kit.
This article was produced with AI assistance and reviewed by a human editor. Figures are linked to their primary sources.
