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Sep 25, 2026

Open Enrollment already asks a lot of brokers. This year, there’s another important process to prepare for: ID proofing.

CMS is introducing new verification requirements for both brokers and consumers. This article focuses on the consumer ID-proofing process: what it means for broker-assisted enrollments and how brokers can help clients complete it smoothly.

New identity-verification requirements for consumers are adding steps to certain broker-assisted Marketplace enrollments. While the policy is designed to help protect consumers and the integrity of the ACA Marketplace, it can also introduce new friction into the enrollment process.

For brokers, preparation will be key. Understanding which clients may be affected, setting expectations ahead of an enrollment appointment, and knowing what to do when verification is required can help keep an additional step from becoming an enrollment roadblock.

To break down what’s changing and what brokers can do about it, we spoke with Kip Payne, senior counsel and director of federal affairs, Oscar Health, about what ID proofing is, what it means for brokers and their clients, and how brokers can prepare their books of business ahead of Open Enrollment. He also discusses how Orchard Health Marketplace is approaching the new requirements with a goal to make it easy for brokers to keep their clients moving toward coverage.

What is ID proofing and why was it introduced?

At its simplest, ID proofing is a way to make sure the person enrolling in health coverage is really who they say they are. Think of it as an added identity check built into the enrollment process.

For the 2027 plan year, the Centers for Medicare & Medicaid Services (CMS) is introducing additional identity-verification requirements for certain Marketplace enrollments. Depending on the consumer and their circumstances, they may need to take an extra step to confirm their identity before their broker can complete the enrollment.

Identity verification helps reduce the risk of someone enrolling a consumer, or making changes to their coverage, without that person’s knowledge or permission. That added protection is important, but it also changes the enrollment experience for brokers and their clients. The challenge and the opportunity for platforms like Orchard is making that extra step as clear and seamless as possible.

How does the ID proofing process work?

The easiest way to think about the ID proofing process is that it adds a verification step between starting an application and completing an enrollment. The exact experience depends on the client, but from a broker’s perspective, the basic flow is pretty straightforward.

You’ll start the enrollment the way you normally would by finding your client and their application in the enrollment platform. From there, the Marketplace determines whether the client falls into a higher- or lower-risk category based on criteria set by CMS.

For a lower-risk client, the process is relatively simple and ID proofing is not required, but broker authorization is still necessary. The client receives a one-time passcode, or OTP, using their contact information on file. They use that code to authorize you to continue working on their behalf, and then you can move forward with the application and enrollment.

For a higher-risk client, there’s an additional step – this is the ID proofing portion. The client receives a link to complete identity proofing themselves. Once their identity has been verified, they’ll receive the one-time passcode needed for broker authorization. After that authorization is complete, you can continue with the enrollment.

That distinction is important because a client doesn’t necessarily have to do something wrong or unusual to fall into the higher-risk group. For example, CMS criteria can include someone who is new to ACA coverage, is seeking coverage in a different state, is working with a different broker, or has an active enrollment with a net premium of $30 or less per month after their tax credit. Meeting just one of the high-risk criteria can trigger the additional identity-proofing step.

For brokers, the biggest takeaway is to prepare the client so they know what to expect.

What can brokers do now to prepare?

EDE platforms are required to implement the new identity-proofing and broker-authorization requirements no later than October 12, 2026, giving brokers a short window to prepare before Open Enrollment begins. ID proofing and broker authorizations are much easier to manage when you’ve done some of the groundwork ahead of time, rather than discovering an issue while a client is sitting with you trying to enroll.

First, get familiar with which clients may be more likely to need the additional identity-proofing step. Meeting just one of CMS’s higher-risk criteria can trigger additional identity verification.

Next, make sure your clients’ contact information is up to date and, just as importantly, that they can access it. The verification process may require the client to receive a link or one-time passcode, so an old phone number or an email address they can’t get into can quickly become a roadblock.

It’s also worth setting expectations with clients before their enrollment appointment. Let them know that they may be asked to verify their identity, that it’s a normal part of the Marketplace process, and that they may need to participate in real time. Ask them to have access to their phone and email and to bring any identity documents they need. A little education ahead of time can prevent a lot of confusion when you’re trying to get an enrollment across the finish line.

For brokers managing a larger book of business, I’d think about this as a workflow rather than a one-off task: identify who may be impacted, confirm you can reach them, prepare them for what to expect, and have a plan for what you’ll do if verification doesn’t work on the first try. That same approach works whether you’re an independent broker managing your own book or part of a larger agency with hundreds or thousands of clients.

The goal isn’t for brokers to become experts in identity verification. It’s to remove as many surprises as possible before Open Enrollment starts. The more preparation you can do now, the more time you can spend during OE doing what you actually want to be doing: helping clients understand their options and get enrolled in the right coverage.

How is Orchard helping brokers navigate ID proofing this Open Enrollment?

ID proofing is one of the biggest changes we’re preparing for this Open Enrollment. Our focus is making sure the experience works well on both sides: brokers need to understand the process and feel confident guiding their clients through it, while consumers need to be able to complete the steps themselves without unnecessary confusion or friction.

To support this, we recently launched a new identity proofing feature that allows agents to send an account creation request directly to their clients. Once a client creates their account and successfully completes the initial ID proofing process, they remain verified for future open enrollment periods on Orchard, eliminating the need to repeat this step in subsequent years. This streamlined process relies on dynamic information such as ZIP codes, IP addresses, and personal history to verify identity, rather than requiring the client to provide a photo ID.

Click to watch the demo below:

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We know brokers are completing the same workflows over and over again during Open Enrollment, so even small points of friction can add up quickly. Whether it’s ID proofing, shopping for plans, enrolling a client, or moving a book of business onto the platform, Orchard is simplifying the process and removing unnecessary manual work.

Ultimately, the goal is to make Orchard a platform where brokers can spend less time navigating technology and more time serving and growing their business. ID proofing is a good example of that. We can’t remove the requirement, but we can design the experience around it so that an added compliance step creates as little disruption as possible for brokers and their clients.

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