Anyone applying for an Affordable Care Act Marketplace plan through an insurance agent or broker must now supply a Social Security number or an immigration document number for every person on the application except a newborn, under a new identity check the Centers for Medicare & Medicaid Services announced this month. CMS paired the requirement with a broader anti-fraud push that already canceled roughly 315,000 enrollments it deemed unauthorized. The agency describes the change as a way to stop agents and brokers from enrolling people without their knowledge.
The new ID rule skips Medicare, but the paperwork habit doesn’t: anyone moving from Marketplace coverage into Medicare at 65 inherits its own document trail, which the 51 state cost-help packs in The Medicare Cost & Coverage Protection Kit are organized around. See the state cost-help pack for coverage paperwork →
The New Agent and Broker Requirement
CMS’s anti-fraud fact sheet requires an agent- or broker-submitted Marketplace application to include a Social Security number or an immigration document number for every applicant named on the policy, with one exception: a newborn does not need either number listed. The fact sheet also adds an electronic consumer authorization step, meant to confirm that the person named on the application actually agreed to be enrolled, before an agent or broker can complete a Marketplace submission for someone else. CMS says the combined change closes a gap that showed up repeatedly in consumer complaints, from people who discovered a Marketplace policy, and in some cases a monthly premium bill, that they had never agreed to.
Why CMS Says the Change Was Needed
CMS’s September 22, 2026 press release ties the new requirement to a cleanup already underway: the agency canceled approximately 315,000 enrollments covering more than 760,000 people as of August 31, 2026, after finding brokers had signed people up without proper authorization. CMS estimated roughly $2.2 billion in advance premium tax credit payments were tied to those canceled enrollments, money the release says taxpayers effectively covered for coverage the enrollees never asked for. Fierce Healthcare’s contemporaneous reporting on the cancellations put the same 760,000-person figure at the center of the story, describing it as one of the largest single Marketplace cleanups CMS has carried out.
The Administration’s Own Framing
Dr. Mehmet Oz, the CMS Administrator, was quoted in the press release saying fraud in the program takes money away from hardworking taxpayers, a line CMS itself used to justify tightening the application process rather than only penalizing individual brokers after the fact. The press release’s own headline calls the effort a crackdown on fraud, waste and abuse, and the fact sheet frames every new requirement, from the identification rule to a broker registration pause, as part of the same initiative rather than as separate, unrelated fixes.
What Happens to the Brokers Involved
Beyond the application changes, CMS said it has terminated more than 200 agents and brokers from Marketplace access since January 2026 and sent 569 additional termination notices over the summer. The agency also described a 2027 registration moratorium for new agents and brokers seeking Marketplace access, alongside a re-verification step through Login.gov for any broker who wants to keep working with Marketplace applicants going forward. A broker who cannot complete that re-verification loses the ability to submit Marketplace applications on a consumer’s behalf at all, and CMS says the moratorium on new agent and broker registrations for 2027 is meant to slow the addition of new accounts while the re-verification process for existing ones works through its backlog.
What the Newborn Exception Covers
The exception is narrow: it applies specifically to a newborn being added to an existing or new Marketplace application, reflecting the reality that a Social Security number is not always issued immediately after birth. Every other person on the same application, including older children and other dependents, still needs a Social Security number or an immigration document number listed before an agent or broker can submit the enrollment on the household’s behalf. Someone applying directly through HealthCare.gov rather than through an agent or broker is not described in CMS’s fact sheet as subject to this particular new step, since the requirement is aimed specifically at the agent- and broker-assisted application channel where CMS says most of the unauthorized enrollments originated.
How the Enrollments Were Found in the First Place
CMS’s fact sheet describes the unauthorized enrollments as the product of a targeted review rather than a routine audit, cross-referencing agent and broker submission patterns against consumer complaints and unusual enrollment volume tied to individual agents. An application flagged through that review triggered the cancellation process the release describes, with the enrollee’s coverage ending and any associated subsidy payments treated as recoverable. CMS has not published a state-by-state breakdown of where the 315,000 canceled enrollments were concentrated, so it is not yet possible to say whether particular states or particular brokers accounted for a disproportionate share of the total. The fact sheet does say the review will continue on a rolling basis, meaning additional enrollments could still be flagged and canceled after this initial round, separate from the ongoing broker termination and re-verification process.
Carrying Coverage Paperwork From the Marketplace Into Medicare
CMS’s new identity check applies only to agent- and broker-submitted Marketplace applications, not to Medicare, but the underlying problem it is trying to solve, an enrollment record nobody can fully verify later, is one that follows people who later switch from Marketplace coverage to Medicare at 65 and have to reconstruct their own coverage history.
The Medicare Cost & Coverage Protection Kit includes 51 state Medicare cost-help packs and a medication and cost tracker, both meant to keep a coverage and cost record straight once Medicare eligibility begins.
Log a coverage document trail before the next renewal →
This article was drafted with AI assistance and reviewed by a human editor before it went live.
