NAIFA strongly opposes any proposal that would place a moratorium on new agent and broker registrations for ACA Marketplace plans for Plan Year 2027.
NAIFA fully supports eliminating fraud where it exists in the ACA marketplace. Bad actors harm consumers, undermine trust in the system, and reflect poorly on the vast majority of licensed professionals who work with integrity every day. However, a moratorium on new agents and brokers is a drastic, ill-advised step that would not effectively achieve that goal. It penalizes the many for the actions of a few and does little to stop those already engaged in misconduct.
Agents and brokers are an essential part of the enrollment experience. Choosing a health coverage option is a difficult decision, one that requires consumers to balance premiums, deductibles, co-pays, provider networks, and prescription drug coverage, among other factors. CMS itself reported that 78% of enrollments in federally facilitated Marketplace states during the 2026 OEP were assisted by an agent or broker. Many consumers rely on licensed advisors to help them navigate this process, and a moratorium would shut out qualified new professionals, leaving people with less access to guidance when they need it the most.
Rather than adopting a sweeping moratorium, NAIFA encourages CMS to pursue a more targeted and deliberate approach that goes after bad actors directly while keeping qualified professionals in the Marketplace. To this end, we ask CMS to consider how enrollment processes and approvals differ between the Medicare and ACA markets. The Medicare enrollment framework has distinct safeguards involving carrier-based certification and appointments, testing and training, and documentation requirements, which can offer a more effective and less disruptive way to protect ACA consumers.
NAIFA shares CMS's goal of a marketplace that is safe, transparent, and fair. We stand ready to work with the agency on solutions that actually stop fraud without limiting consumers' access to the professional guidance they need and deserve.