One Missing Detail Could Impact Your Passive Renewals

Oct. 14, 2026

Applies to Individual & Family Markets

A smooth renewal experience starts with accurate consumer information. To help reduce unauthorized and non-compliant Marketplace enrollments, the Centers for Medicare & Medicaid Services are adding a new verification step to the passive renewal process for 2027.

Taking action now can help ensure your clients experience a seamless renewal and help protect your ability to continue receiving commissions on eligible enrollments.

What's Changing

As part of the 2027 passive renewal process, CMS will review applications that include a National Producer Number to confirm they meet existing identity verification requirements.

If an application does not include a verified Social Security number or verified immigration document information for each non-newborn applicant, the consumer may still be automatically renewed for 2027. However, CMS will remove the agent or broker NPN from the enrollment.

What You Need to Do

Before Open Enrollment begins, review your 2026 Marketplace book of business and identify applications that may be missing required verification information.

To avoid NPN removal:

• Ensure each non-newborn applicant has a verified SSN on file.
• Ensure each non-citizen applicant has verified immigration document information on file.

If a consumer updates their 2027 application and actively re-enrolls by Dec. 15, 2026, the NPN will remain associated with the enrollment.

Important Reminders

• A verified SSN is required for applicants older than 90 days.
• If a non-citizen applicant does not provide an SSN, verified immigration documentation must be provided.
• Agents and brokers may not create, access or maintain consumer HealthCare.gov login credentials.
• Agents and brokers should not identify themselves as Navigators, Certified Application Counselors or other assister types when helping consumers complete applications.

Act Early

The sooner you review and update affected applications, the easier it will be to navigate passive renewals and prepare for a successful 2027 Open Enrollment season.

Questions?

Contact the CMS Agent/Broker Help Desk.