This pre-open-enrollment checklist covers what CMS told agents to do before ACA open enrollment opens November 1, 2026. The rules for connecting to your clients are tighter this year, the enrollment window is shorter, and the prep that used to wait until October now needs to happen in September.
If you want a clean open enrollment instead of a chaotic one, here is the work to do now.
Two things changed the timing. First, open enrollment for 2027 coverage is shorter. The federal marketplace window runs November 1 to December 15, down from the longer window agents worked with in past years. Fewer days means less room to fix problems mid-enrollment.
Second, CMS is tightening how agents connect to consumers. At the 2026 Agent Summit and in an August FAQ, CMS laid out new identity and authorization steps that have to be in place before you can work a client's application. If those are not sorted before November 1, you lose time you do not have.
CMS put it simply. The best thing you can do now is reach as many of your clients as possible, know where they live and how to contact them, and get your own credentials and authorizations in order early.
Work through these before November 1.
This is the step CMS named first. Contact every client and confirm you have current phone, email, and address. A shorter window means you cannot afford to chase bad contact info in November. Reconnecting now also surfaces the clients most at risk from premium increases so you can plan those conversations early.
CMS is implementing consumer identity proofing this year and tightening how agents are verified. Make sure your own identity verification and marketplace credentials are current and active. Do not assume last year's setup still works. One lapsed credential can block you from enrolling clients on day one.
This is the biggest change. CMS is moving toward a system where you are explicitly linked to a client through a documented authorization, and it will limit your access to a client's account until that client has authorized you to work on their behalf. Whichever EDE platform you use, confirm you understand its authorization process and start capturing client consent now rather than scrambling in November. Historically an agent could be tied to a client through a National Producer Number, but CMS has been tightening how NPNs attach to applications, so the documented authorization is what matters going forward.
CMS asked agents directly to be as accurate as possible with client income estimates. With pre-enrollment verification expanding, a sloppy income figure can stall an application or cost a client their subsidy. Take the time to get it right the first time.
If a client has a data-matching issue, an income or identity discrepancy the marketplace flags, resolve it before open enrollment rather than during it. These take time to clear, and a backlog of them in November will bury you. Pull your list of clients with known issues and start working them now.
CMS is reinstating pre-enrollment verification for Special Enrollment Periods and adding income documentation requirements in certain cases. A proposed rule with more detail is expected in the coming months. You do not need to act on the proposed rule yet, but set the expectation with clients now that verification may be part of the process, so a documentation request does not catch anyone off guard.
When the window opens, you want to move fast. Make sure your quoting and comparison setup is current and loaded with 2027 plans for your counties so you are not learning your tools during the busiest weeks of the year. The agents who walk in with comparisons ready spend open enrollment enrolling, not troubleshooting.
Open enrollment for 2027 opens November 1 and closes December 15, a shorter window with tighter agent authorization rules than last year. The agents who reach their book now, get their identity and authorizations in order, clear data-match issues early, and load their comparisons ahead of time will have a calm open enrollment. The ones who wait until October will spend the season reacting. Start the checklist now.
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Disclaimer: This post is for educational purposes only and reflects information available at the time of publication.