ACA Open Enrollment Checklist for Agents: What to Finish First

Your ACA Open Enrollment Checklist for Agents at a Glance

Here is the full list in the order to tackle it. Each item gets its own section below.

1. Finish Plan Year 2027 Marketplace registration and training, then print your certificate.
2. Verify your NPN on the Registration Completion List (RCL) and fix any profile errors.
3. Confirm resident and nonresident licenses, health LOA and CE status in every state you sell.
4. Review carrier appointments against 2027 entries and exits, and flag affected clients.
5. Update intake so consent, consumer authorization and applicant SSNs are captured and stored.
6. Test your CRM, quoting and enrollment handoff from end to end.
7. Load follow-up sequences for new leads, renewals, quoted-not-enrolled households and no-shows.

Treat the start of open enrollment as the deadline for being finished, not the day you start. Confirm exact enrollment dates for each state you work, because state-based marketplaces can set their own windows.

Agent Certification (FFM): Finish Registration Early

Start here, because nothing else matters if you can't get into Marketplace systems. According to CMS's registration and training page for agents and brokers (opens in a new tab), Plan Year 2027 registration and training is available for returning agents and brokers on the Marketplace Learning Management System (MLMS), in English and Spanish. Agents who completed Plan Year 2026 Individual Marketplace training are eligible for a shorter 2027 training plus optional review modules.

The CMS returning agents' guide to Plan Year 2027 registration and training (opens in a new tab) lays out seven steps:

1. Create Login.gov or ID.me credentials.
2. Link your MLMS profile.
3. Request the Agent Broker Training role.
4. Complete your MLMS profile.
5. Complete training.
6. Sign the required agreement(s).
7. Confirm your registration status and print your certificate.

Two details in that guide can cost you money. If you skip the linking process in steps one and two, you will be blocked from getting the role and accessing the MLMS. And entering an inaccurate individual NPN, or copying your individual NPN into the business and web-based entity fields, may result in denial of compensation or credit by an issuer.

Per the CMS guide, registration can take one to two business days to appear on the Registration Tracker and RCL, and up to three business days on Find Local Help. If your NPN still isn't on the Plan Year 2027 RCL, email FFMProducer-AssisterHelpDesk@cms.hhs.gov.

CMS posts the RCL as frequently as daily, so check it yourself rather than assume. Completed registration is also what makes you eligible for Help On Demand. One more rule from the guide: never share your credentials, passwords or MFA details, even with your own staff.

New or Lapsed? Check the 2027 Registration Moratorium

According to Health Affairs' analysis of the CMS interim final rule (opens in a new tab), CMS published a rule on September 22, 2026 pausing new agent and broker registration ahead of the 2027 plan year. It applies to those not already registered with the federal marketplace and does not apply to agents supporting enrollment through state-based marketplaces.

The same analysis says the moratorium took effect immediately and is set to expire on February 1, 2027, unless CMS ends it earlier, extends it or modifies it. CMS is accepting comments until November 21 and may change the policy in response. If you're new to the FFM, plan this season around state-based marketplace states where you're licensed and watch for CMS updates.

Licenses, Carrier Appointments and the 2027 Carrier Map

An FFM certificate doesn't replace a state license. CMS's registration page states that agents without an approved health-related Line of Authority, as determined by their resident state, don't have access to Marketplace systems and can't assist consumers with Marketplace enrollment.

• Pull your record from the NIPR Producer Database and confirm every resident and nonresident license is active with a health LOA.
• Confirm CE is complete and no renewal date lands in the middle of the season.
• List every carrier you're appointed with by state, and confirm 2027 contracting is active.
• Make sure your NPN and agency details match across carriers, your MLMS profile and your enrollment platform.

Then look at who is coming and going. According to KFF's tracker of 2027 insurer participation changes (opens in a new tab), as of October 7, 2026, 11 carriers have announced they will exit the ACA Marketplaces in some or all of their states for plan year 2027, and six have announced they will enter new state Marketplaces. KFF reports Cigna will leave the individual market in 2027, exiting the 11 states where it currently participates on and off exchange.

Turn Carrier Exits Into a Renewal Plan

1. Filter your book by carrier and state, and tag every household on an exiting carrier.
2. Get contracted with entering carriers in your states before OEP where possible.
3. Send affected clients a short heads-up before OEP with a booking link.
4. Schedule those reviews in the first weeks of the season, before your calendar fills.

KFF also notes that the expiration of enhanced premium tax credits at the end of 2025 drove sign-ups to fall by over a million from the 2025 to 2026 Open Enrollment Periods. Expect price-sensitive renewals, and have a simple side-by-side comparison ready for budget conversations.

Update Consent and Documentation for 2027 Rules

This section is general information, not legal advice. Confirm the details with your compliance resources, carriers and upline.

The CMS fact sheet on Federal Marketplace anti-fraud actions (opens in a new tab) lists the changes that touch your workflow most. All existing agents and brokers must re-identity proof through Login.gov or ID.me. Applications involving an agent or broker must include SSNs or immigration document numbers CMS can verify for all non-newborn applicants. And in advance of Open Enrollment, CMS will require electronic consumer authorization before an agent or broker can take any action on an application or enrollment.

CMS is enforcing, too. The same fact sheet says that since January 2026 CMS has sent termination notices to over 200 non-compliant agents and brokers, and this summer issued 569 notices of intent to terminate Exchange Agreements to agents and brokers that submitted 2026 applications without identifying applicant information such as an SSN.

• Add SSN or immigration document number fields for every non-newborn applicant to your intake, and tell consumers upfront why you need them.
• Map where electronic consumer authorization fits your call flow so it's done before you touch the application.
• Ask for permission to contact and permission to act on the Marketplace separately, and store each with a date and time.
• Pull any ad or landing page that implies government affiliation or makes claims you can't support for every consumer.

Open Enrollment Preparation for Your Systems

Test the whole path a lead takes, from first click to submitted application, while volume is low. Run this test once now and again a week before OEP.

1. Submit a test lead through every form and ad you plan to run.
2. Confirm it lands in your CRM with source, ZIP, county, household size and consent status.
3. Check that tags move the lead to the right pipeline stage and fire the right notifications.
4. Quote a real county and confirm plans and premium tax credit pricing display correctly.
5. Open your enrollment platform from the lead and confirm the handoff works under your NPN.
6. Retrieve the consent record for that test lead in under a minute.

If you're still deciding where this season's leads come from, compare exclusive versus shared health insurance leads before you commit budget. If you plan to run ads, launch and test them weeks ahead; our Facebook ads playbook for ACA agents covers setup.

This is the setup FastTrack builds for agents: a branded quote funnel on your own domain under your NPN, permission to contact and permission to act on the Marketplace signed separately and filed as PDFs, a GoHighLevel sub-account configured for ACA before you log in, and HealthSherpa opening prefilled for each quoted household.

Build Your OEP Follow-Up Before the Rush

According to HubSpot's guide to automating follow-up emails (opens in a new tab), fifty percent of all sales happen after the fifth follow-up attempt, a figure HubSpot attributes to Inside Sales. That's general sales data, not ACA-specific, but the lesson holds: most agents stop too early, and OEP volume makes it worse.

Automation fixes this. Each sequence starts from a trigger, such as a new tag or a missed appointment, and sends pre-written messages on a schedule. Write and test them now, not in week two of OEP.

Sequences to Load Now

• New lead, not reached: an immediate text, then call attempts spread across several days.
• Quoted, not enrolled: a reminder with the plan they liked and a link to book a call.
• Renewal outreach: a pre-OEP message to every active client inviting a review.
• Carrier exit: a specific message for households whose carrier is leaving.
• No-show: an automatic reschedule link sent shortly after the missed time.
• Post-enrollment: a reminder to pay the first premium so coverage takes effect.

Example renewal text, for clients who have agreed to receive texts: 'Hi [Name], it's [Agent] with [Agency]. Open enrollment is coming up and 2027 plans and prices may change for your household. Want to book 15 minutes to review your options? Reply STOP to opt out.'

Get Your OEP Pipeline Ready This Week

Pick the first unchecked item on this list and finish it today: certification first, then licenses and carriers, then consent, systems and follow-up. Agents who arrive at open enrollment with all of it done spend the season enrolling instead of fixing. For more on filling the pipeline, see our guide on how to generate ACA leads.

If you'd rather have the funnel, consent capture, CRM and ads built for you on your own accounts, set up your FastTrack ACA lead system online in one sitting, with no sales call.