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Call the Affordable Care Agents team at (646) 233-1499 for live, step-by-step support with your CMS Enterprise Portal account, MLMS training, carrier appointments and AHIP. Our team can walk you through each step.
What Just Happened?
Short answer: On November 5, 2026, the U.S. District Court for the District of Maryland granted a preliminary injunction that lifted the CMS moratorium on new agent and broker registration for the federally facilitated Marketplace. On November 6, CMS made Plan Year 2027 registration and training available to new agents and to agents who did not complete Plan Year 2026 registration. They can now certify and help clients during Open Enrollment.
The cases were brought by two trade groups, the National Association of Benefits and Insurance Professionals (NABIP) and Health Agents for America (HAFA). U.S. District Judge Stephanie Gallagher found that the groups were likely to win on their claims under the Administrative Procedure Act. She also found that their members would likely suffer irreparable harm without relief and that lifting the freeze served the public interest, according to reports in Healthcare Dive and HealthExec. InsuranceNewsNet reported that the order also requires CMS to make training and registration available to new agents.
CMS moved quickly. Its Marketplace registration and training page now says Plan Year 2027 registration and training “is now available for new and returning agents and brokers” in the Marketplace Learning Management System (MLMS), in English and Spanish. CMS also posted a new New Agents and Brokers Guide to Plan Year 2027 Marketplace Registration and Training dated November 2026.
Why this matters so much right now
The freeze was set to last until February 1, 2027, after Open Enrollment would end. Lifting it now gives newly eligible agents about five and a half weeks before the December 15 deadline for January 1 coverage, and about ten weeks before Open Enrollment closes on January 15, according to HealthCare.gov. That window is valuable. Consumers face a tougher market this year, including higher benchmark premiums, carrier exits and the return of the 400% FPL subsidy cliff, as KFF explains. Many will be looking for a licensed professional to help.
Broker Takeaway
If you are not yet certified for 2027 on the federal Marketplace, start today. Registration has several steps, and your name can take 1 to 3 business days to appear on CMS lists after you finish. Every day you wait is a day you can’t enroll clients.
Who Needs to Act Now
Not every agent is affected by the ruling. Use this table to see where you stand.
CMS’s guide is clear that agents who are new, or who skipped Plan Year 2026, “must take the full Individual Marketplace training for Plan Year 2027.” Returning agents who completed Plan Year 2026 can take a shorter training, according to the CMS registration page.
Broker Takeaway
Medicare brokers who sat out the ACA market last year are among the biggest winners from this ruling. You can now serve the under-65 family members, early retirees and self-employed clients you already know.
How We Got Here: The Timeline
For background on why CMS imposed the freeze, see our original coverage of the CMS moratorium. CMS argued the pause was needed while it strengthened safeguards against unauthorized enrollments. That concern hasn’t gone away, and it shapes how carefully every new agent should work this season.
Seven Steps to Register and Certify for 2027
These steps follow the CMS new-agent guide. Set aside a focused block of time. The training includes required courseware and exams.
- Create an ID.me or Login.gov account. Go to the CMS Enterprise Portal, select “Sign In,” and choose ID.me or Login.gov. You only need one. You’ll complete identity proofing to confirm you are the account holder.
- Link your old account, if you had one. If you ever had a CMS Enterprise Portal (IDM) account, link it to your new ID.me or Login.gov sign-in. Make sure your IDM password works first. CMS warns that skipping this step will block you from the training role and the MLMS. If you are completely new, skip to step 3.
- Request the Agent and Broker Training Access role. Search “Fed,” choose the “Federally Facilitated Marketplace (FFM)/Request for MLMS Training Access” tile, accept the terms, and select “Agent Broker Training Access.”
- Complete your MLMS profile. Open “Marketplace Training – Agent Broker,” choose the “Agent Broker” role, set your Find Local Help and Help On Demand preferences, and enter your National Producer Number (NPN) carefully.
- Complete your training. Enroll in the Individual Marketplace training (and SHOP, if you serve small groups), then open the curriculum and finish all modules and exams.
- Sign the required agreements. Read each agreement and select “I Agree.”
- Print your certificate and confirm your registration. Download your PY2027 certificate. Then check the Agent and Broker Marketplace Registration Tracker and the FFM Registration Completion List (RCL), where you should appear within 1 to 2 business days, and Find Local Help, which can take up to 3 business days.
If your NPN doesn’t appear on the PY2027 Registration Completion List, CMS says to email [email protected]. Our team can also help you troubleshoot. Call (646) 233-1499.
After CMS: carrier certifications and appointments
Finishing CMS registration doesn’t mean you’re ready to write business. Most Marketplace carriers also require their own certification, appointment or onboarding before they pay commissions. Carriers set those requirements, and they vary by state, so confirm each one before you enroll a client. Also review the 2027 consumer consent rules in our 2027 consumer authorization and ID-proofing guide.
Broker Takeaway
Don’t take a single Marketplace application until your name appears on the RCL and your carrier appointments are active. Enrollments submitted before then can be denied credit.
Don’t Forget Your Medicare Certifications
Many of the brokers this ruling helps also sell Medicare, and the Medicare Annual Enrollment Period ends on December 7. If you still need AHIP for 2027, you can complete it at a discount through our office link: AHIP 2027 Medicare training at the Affordable Care Agents discount. Then finish each carrier’s 2027 certification so you are ready-to-sell before your next appointment.
For the details, see our AHIP 2027 certification guide and our list of 2027 Medicare carrier certification dates.
Broker Takeaway
Certify on both sides now. Many households have one spouse on Medicare and the other under 65, and a broker who can serve both keeps the whole household.
Mistakes That Can Cost You Commissions
- Entering your NPN in the wrong field. CMS warns that an individual NPN copied into the business or web-based entity field “may result in denial of compensation or credit by an issuer.”
- Skipping the account link. Agents with an old IDM account who don’t link it get stuck and can’t reach the MLMS.
- Sharing login credentials. CMS reminds agents never to share credentials, passwords or MFA details. You are the only person who should use your FFM User ID.
- Enrolling before you’re on the RCL. Wait the 1 to 2 business days and confirm your status first.
- Ignoring consumer consent rules. Document consent and follow the 2027 authorization requirements on every application.
- Waiting until December. System slowdowns and support queues get worse closer to deadlines.
What the Ruling Does Not Change
This is a preliminary injunction, not the end of the case. HAFA said the decision was a victory but that “this fight is far from over,” according to Healthcare Dive. Court orders can be appealed or modified, so brokers should watch for official updates from CMS before relying on any change in status.
- CMS’s program-integrity focus remains. Expect close review of new-agent enrollments.
- Consumer consent, documentation and ID-proofing requirements still apply.
- State licensing, appointment and state-based exchange rules are unchanged.
- Subsidy rules for 2027 are unchanged, including the 400% FPL cliff and the end of repayment caps.
For the full 2027 Open Enrollment picture, including dates and subsidy changes, see our ACA Marketplace OEP 2027 broker guide and ACA subsidy cliff guide.
Broker Takeaway
Treat this season as a fresh start under a microscope. Clean documentation, careful income estimates and proper consent protect your clients, your commissions and your license.
Call Our Team for Live Support
Affordable Care Agents is a national FMO, IMO and insurance brokerage. If you’re new to that model, here’s what an FMO does for brokers. Right now we’re focused on getting brokers certified and selling fast, with:
- Live phone support while you complete CMS Enterprise Portal, MLMS and agreement steps
- Marketplace carrier contracting and appointment help
- AHIP 2027 at a discount through our OIM partnership, plus Medicare carrier certification support
- Compliance guidance on consumer consent, documentation and suitability
- Back-office support through Open Enrollment and AEP
Get Certified Today. We’ll Walk You Through It.
Call our team at (646) 233-1499 for live support with 2027 Marketplace registration, carrier appointments and AHIP. You don’t have to figure it out alone.
Need AHIP 2027? Complete it at a discount through our office link.
Frequently Asked Questions
Disclaimer: This article is provided for educational and informational purposes only and should not be considered legal, tax, financial, medical, insurance, or compliance advice. Insurance laws, Medicare and Medicaid regulations, Affordable Care Act Marketplace rules, carrier policies, commissions, plan availability, eligibility requirements, and state regulations may change and may vary by jurisdiction. Readers should verify current information through official sources such as CMS, Medicare.gov, Healthcare.gov, IRS.gov, state Departments of Insurance, and applicable insurance carriers before making insurance or business decisions. Affordable Care Agents is a national FMO, IMO, and insurance brokerage. Publication does not constitute an offer of insurance or a guarantee of coverage, contracting, compensation, eligibility, or regulatory compliance. We are not connected with or endorsed by the U.S. government or the federal Medicare program.
