The Centers for Medicare & Medicaid Services canceled approximately 315,000 federal Affordable Care Act health insurance marketplace enrollments covering more than 760,000 people after determining they were unauthorized, confirming a significant CMS unauthorized marketplace enrollments $2.2 billion recovery effort announced Sept. 22.
The Scale of This CMS Unauthorized Marketplace Enrollments $2.2 Billion Crackdown
CMS expects to recover roughly $2.2 billion in taxpayer-funded subsidies. The cancellations occurred Aug. 31 following reviews by CMS and health insurers, according to an agency fact sheet. The anticipated recovery involves advance payments of premium tax credits associated with those enrollments.
Why CMS Hasn’t Named Specific Wrongdoers
CMS did not specify the wrongdoers, but said it would hold agents and brokers accountable. “CMS is strengthening safeguards, pursuing bad actors, and holding agents and brokers accountable when they break the rules,” HHS Secretary Robert F. Kennedy Jr. said in the announcement, a framing that places responsibility on enrollment intermediaries rather than naming individual bad actors publicly at this stage.
The Registration Moratorium Within This CMS Unauthorized Marketplace Enrollments $2.2 Billion Effort
CMS also imposed a temporary registration moratorium for agents and brokers seeking to participate in the 2027 federal marketplace who lack a 2026 exchange agreement. The pause lasts until Feb. 1, 2027, unless CMS lifts it earlier, extends it, or modifies it through a subsequent notice.
Why This Moratorium Targets New Registrants Specifically
By limiting the moratorium to agents and brokers without an existing 2026 exchange agreement, CMS is targeting new market entrants specifically, rather than imposing broad restrictions on brokers who already hold established, compliant relationships with the federal marketplace.
Enforcement Actions Already Taken Within This CMS Unauthorized Marketplace Enrollments $2.2 Billion Effort
Since January, CMS has issued termination notices to more than 200 agents and brokers for noncompliance. Separately, the agency said it sent 569 notices of intent to terminate this summer over applications missing identifying information. Of the first 100 cases whose response periods ended, 66 resulted in termination notices, according to the fact sheet.
The New Identity Verification Requirements
CMS is requiring existing agents and brokers to verify their identities again through Login.gov or ID.me. Applications involving agents or brokers must include verifiable Social Security or immigration document numbers for applicants other than newborns. Before open enrollment, CMS plans to require electronic consumer authorization before agents or brokers can act on applications or enrollments.
Industry Reaction to This CMS Unauthorized Marketplace Enrollments $2.2 Billion Crackdown
The National Association of Benefits and Insurance Professionals raised concerns about the measures, saying the immediate changes came without an advance public comment period or meaningful notice ahead of open enrollment. The association supports targeted enforcement and stronger verification requirements but warned that restricting registrations could reduce consumers’ access to enrollment assistance.
NABIP’s Call for Balance
“We can protect program integrity while also protecting eligible consumers and their access to trusted, licensed professionals,” NABIP President Mychal Walker said in a statement, reflecting the association’s effort to support the underlying anti-fraud goal while flagging concerns about implementation timing and process.
The Broader Trend Behind This CMS Unauthorized Marketplace Enrollments $2.2 Billion Crackdown
A July Government Accountability Office review called for stronger CMS safeguards against unauthorized marketplace activity. Confirmed complaints about unauthorized enrollments and plan switches increased from 66,548 in 2023 to 299,604 in 2025, and GAO identified weaknesses in how CMS verifies consumer consent and notifies people about activity on their accounts.
Prior Enforcement Steps Leading to This Crackdown
CMS in June cracked down on improper ACA enrollments in its final rule, building on earlier action from July 2024 when the agency restricted broker access to HealthCare.gov enrollments, requiring agents not already associated with an enrollment to take additional steps, such as joining a three-way call with the consumer and the Marketplace Call Center, before making changes.
What This CMS Unauthorized Marketplace Enrollments $2.2 Billion Crackdown Means Going Forward
With confirmed unauthorized enrollment and plan-switch complaints nearly quintupling from 2023 to 2025, this $2.2 billion recovery effort represents CMS’s most significant enforcement action yet in a multi-year pattern of tightening ACA marketplace oversight. Given NABIP’s specific concern about reduced consumer access to enrollment assistance, brokers and agents navigating the new identity verification and electronic consumer authorization requirements should prepare for potential disruption to their workflows ahead of the upcoming open enrollment period.
What to Watch Going Forward
As the Feb. 1, 2027 registration moratorium deadline approaches, industry observers will likely watch whether CMS extends or modifies the pause, and whether the new Login.gov and ID.me identity verification requirements meaningfully reduce the unauthorized enrollment complaints GAO documented rising so sharply between 2023 and 2025. Given the broader pattern of CMS anti-fraud actions across DMEPOS suppliers, hospice and home health enrollment, and now ACA marketplace enrollments, this CMS unauthorized marketplace enrollments $2.2 billion crackdown adds to a sustained, multi-front federal enforcement push spanning nearly every major corner of the Medicare and Medicaid ecosystem throughout 2026.
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