ACA Open Enrollment 2027: Stricter ID Checks and Fewer Brokers

Open enrollment for Affordable Care Act coverage begins for most states on Saturday, marking the start of the selection period for 2027 health plans. The window opens earlier in Idaho, Connecticut, and Massachusetts. While the core structure of the marketplace remains, the rules governing how consumers enroll and how agents operate have shifted significantly.

The Centers for Medicare & Medicaid Services has introduced stricter identity verification requirements for people using agents or brokers on the federal marketplace. These rules apply to the 29 states served by the federal platform but do not extend to state-based exchanges. Consumers must receive a one-time confirmation code via text, email, or phone call to authorize a specific agent to act on their behalf. Those deemed high-risk, including first-time applicants and individuals with monthly premiums of $30 or less, must verify their identity through a third party like Experian before proceeding.

Joshua Brooker, a Pennsylvania insurance agency owner, noted that the new scrutiny targets groups where fraud is most common, such as people moving states or switching brokers. He warned that the broad nature of the rules could force up to one in five consumers to undergo extra identity proofing, potentially causing some to abandon the process entirely. Stacey Pogue, a senior research fellow at Georgetown University, agreed that while the measures target fraud, they create additional hurdles for people without established credit files or recent address changes.

A September CMS rule also imposes a moratorium on new brokers entering the ACA market. Agents not registered with the federal marketplace in 2026 cannot assist with 2027 enrollments until February, which is after the open enrollment period ends. CMS cited a disproportionate number of compliance concerns from newly registered agents as the reason for the pause. Jason Fine, a Florida brokerage owner, said the rule makes it harder for small agencies to hire, as they often recruit new staff near the end of the year. He believes the move inadvertently benefits larger call centers that can maintain permanent staffs of 25 to 40 people.

Industry groups have challenged the broker moratorium in court. The National Association of Benefits and Insurance Professionals filed a lawsuit on October 15, arguing the rule unfairly targets 19,000 agents. Health Agents for America filed a separate suit on October 21 seeking a temporary restraining order. Ronnell Nolan, president of the latter group, stated that agencies that trained and paid for new agents now face a workforce that cannot work during the critical enrollment season.

Costs remain a primary concern for shoppers. The expiration of enhanced subsidies at the end of 2025 led to higher out-of-pocket costs for many, although most will still receive some assistance. Premiums are projected to rise by 15% for 2027, a lower increase than the 26% seen last year but still double-digit growth. Subsidies are income-based and cut off for households earning more than four times the federal poverty level, which is $63,840 for a single person and $109,280 for a family of three this year.

Louise Norris, a health policy analyst, said overall affordability for most people should remain similar to this year, assuming they can manage current premiums. However, she advised consumers to compare plans rather than allowing auto-renewal, as coverage details and costs change annually. The out-of-pocket maximums for ACA plans will increase by 13% in 2027, reaching $12,000 for individuals and $24,000 for families. New limits also strip subsidy eligibility from many lawfully present immigrants, including those with H-1B visas or pending green-card applications, while leaving green-card holders and certain refugees eligible.