ACA 2027 Enrollment Opens With New ID Checks and Broker Limits

The Affordable Care Act marketplace enters its annual open enrollment period on November 1, 2026, in most states. Idaho, Connecticut, and Massachusetts began the process earlier this month. Some states also allowed shoppers to preview rates before the official start date.

The Centers for Medicare & Medicaid Services introduced new rules to combat fraud in the federal marketplace. These changes affect consumers in the 29 states that use the federal platform. State-based exchanges maintain their own rules and are not subject to these specific federal requirements.

All consumers using an agent or broker must now receive a one-time confirmation code or link. This code authorizes the specific agent to enroll them or make changes. The code is sent via text, email, or automated phone call from the enrollment platform. Consumers with outdated contact information must update their records directly on healthcare.gov before proceeding.

Consumers classified as high-risk must verify their identity through a third party such as Experian. CMS defines high-risk applicants as first-time enrollees, those changing states, those switching agents, or those paying a monthly premium of $30 or less. Joshua Brooker, an insurance agency owner in Pennsylvania, noted that the $30 threshold targets plans where policyholders might not receive bills, making unauthorized enrollments harder to detect.

Stacey Pogue, a senior research fellow at the Center on Health Insurance Reforms at Georgetown University, warned that the new verification process could create hurdles for those without established credit files or who have recently moved. She described the measures as an appropriate response to fraud that may also increase friction for legitimate shoppers.

A September rule by CMS places a moratorium on brokers new to the ACA marketplace. Agents not registered with the federal marketplace in 2026 cannot assist with 2027 enrollments until February at the earliest. CMS cited a high number of compliance concerns from newly registered agents as the reason for this restriction.

Jason Fine, a brokerage owner in Florida, said the rule creates staffing challenges for small agencies. He plans to hire up to 10 agents but faces a shortage of candidates who were registered in 2026. He suggested the rule benefits larger call centers that can maintain year-round staff. Agent groups have sued the administration, with the National Association of Benefits and Insurance Professionals filing a lawsuit on October 15 and Health Agents for America seeking a temporary restraining order on October 21.

Premiums are expected to rise by 15% for 2027, following a 26% increase in the previous year. Enhanced subsidies that lowered costs for many shoppers expired at the end of 2025. While most consumers will still receive some subsidy, the amount is less generous than during the enhancement period. Subsidies are tied to the cost of the second-lowest silver plan and are income-based.

Households earning more than four times the federal poverty rate lose eligibility for subsidies. For 2027, that income limit is $63,840 for a single person, $86,560 for a couple, and $109,280 for a family of three. The out-of-pocket maximum for 2027 will increase to $12,000 for individuals and $24,000 for families.

The One Big Beautiful Bill Act passed by Congress last year removed subsidy eligibility for many lawfully present immigrants. This includes holders of H-1B visas, refugees, asylees, and those with temporary protected status. Green-card holders and certain Cuban and Haitian immigrants remain eligible for subsidies.