Consumer Authorization: Get It Before You Act

For 2027, the consumer authorizes you before you act — not while, not after. CMS will require electronic consumer authorization before an agent or broker takes any action on an application or enrollment through approved Enhanced Direct Enrollment partners.

The Rule in Plain English

• No authorization on file = no touching the application. Get it first, every time.
• Agents and brokers cannot be added to applications consumers should be completing themselves on HealthCare.gov — systems are being changed to block it.
• Every assisted application must carry verifiable SSNs or immigration document numbers for non-newborn applicants.
• CMS is developing a standardized eligibility/consent form (effective 2028) — build your files as if that audit starts today.

My File Standard

• Recorded or written consent with date, both names, scope/purpose, duration, and how to revoke.
• Authorization captured before the enrollment call, stored with the case, kept for the long CMS retention window.
• STOP means stop — no texts, ever; calls only where appropriate.

What To Do This Month

Run your book top to bottom: who lacks documented authorization for 2027? Work that list weekly until Open Enrollment opens November 1. When in doubt, re-obtain it — a duplicate authorization beats a missing one in any audit.