Brokers serving under-65 (U65) consumers in the Affordable Care Act (ACA) marketplace are facing an unusual gap in 2025. The Federally Facilitated Marketplace (FFM) certification window has closed, and the 2026 training is not yet available.
For many agents, this means waiting until later in 2025 to re-certify with HealthCare.gov. But here’s the opportunity: while FFM certification is paused, many state-based marketplaces (SBMs) are actively offering broker certification for 2025.
By focusing on these states, you can:
- Stay active and compliant.
- Expand your reach into new markets.
- Build relationships that last beyond 2026.
- Strengthen your expertise before the FFM cycle reopens.
This guide explains what you can and cannot do without FFM certification, how to leverage SBMs right now, and includes a state-by-state certification chart to help you act immediately.
What You Cannot Do Without FFM Certification
CMS rules are strict: without certification, you cannot access the agent portal or submit ACA enrollments on HealthCare.gov. Specifically, uncertified brokers cannot:
- Submit new or updated consumer applications.
- Act as the agent of record for FFM enrollments.
- Receive compensation tied directly to uncertified enrollments.
Attempting to bypass these restrictions—such as logging in with a consumer’s credentials or manipulating household details to trigger eligibility resets—is a compliance violation. CMS has increased oversight, and brokers caught using these “shortcuts” risk penalties or loss of certification in the future.
What You
Can
Do in 2025
While you wait for the 2026 FFM training, you can still deliver value and maintain your business.
- Educate: Help clients understand subsidies, plan tiers, and eligibility for Medicaid, Child Health Plus, or Essential Plan.
- Estimate Costs: Use CMS and state cost calculators to show clients what premiums might look like.
- Document Prep: Guide consumers through common requests like income verification, identity proofing (DOH-5088), or immigration paperwork (I-862, PRUCOL).
- Refer Clients: Partner with Navigators or certified colleagues to ensure consumers are supported.
- Get Certified in SBMs: This is the biggest opportunity—several state marketplaces are open for certification in 2025.
Federally Facilitated Marketplace (FFM) States
Most states use the FFM (HealthCare.gov). Certification here is closed for 2025. Agents must wait for the 2026 certification cycle, usually launching in late summer.
| State | Marketplace | Description | Certification Link |
| AL, AZ, DE, FL, HI, IA, IL, IN, KS, LA, MI, MO, MS, NC, NE, NH, OH, OK, SC, TN, TX, UT, WI, WV | Federally Facilitated Marketplace (FFM) | Certification closed for 2025. Agents must wait for the 2026 cycle. | CMS Marketplace Registration & Training |
State-Based Marketplaces (SBM) – Open Certification for 2025
Here’s where you can focus right now. These state marketplaces operate separately from HealthCare.gov and have their own certification processes.
| State | Marketplace | Description | Certification Link |
| California (CA) | SBM CoveredCA | Covered California marketplace | Certification Steps |
| Colorado (CO) | SBM Connect for Health Colorado | Colorado state marketplace | Broker Training |
| Connecticut (CT) | SBM Access Health CT | Connecticut state marketplace | Broker Enrollment |
| District of Columbia (D.C.) | SBM D.C. Health Link | D.C. marketplace | Broker Registration |
| Georgia (GA) | SBM Georgia Access | Georgia state marketplace | Certification Portal |
| Idaho (ID) | SBM Your Health Idaho | Idaho state marketplace | Certification Info |
| Kentucky (KY) | SBM KHBE | Kentucky Health Benefit Exchange | Agent Training |
| Maryland (MD) | SBM Maryland HBE | Maryland marketplace | Broker Certification |
| New Jersey (NJ) | SBM GetCoveredNJ | New Jersey marketplace | Certification Info |
| New Mexico (NM) | SBM beWellnm | New Mexico marketplace | Broker Certification |
| Nevada (NV) | SBM Nevada Health Link | Nevada marketplace (Note: no new non-resident certifications in 2025) | Broker Onboarding |
| New York (NY) | SBM NY State of Health | New York marketplace | Certification Courses |
| Pennsylvania (PA) | SBM Pennie | Pennsylvania marketplace | Certification Info |
| Virginia (VA) | SBM Virginia Marketplace | Virginia Insurance Marketplace | Certification Portal |
| Washington (WA) | SBM WA Health Benefit Exchange | Washington marketplace | Broker Resources |
Why This Strategy Matters
By focusing on SBM states, brokers can:
- Stay compliant while waiting for FFM certification.
- Keep their book of business active and growing.
- Enter new markets and expand their footprint.
- Gain early experience with systems that operate differently than HealthCare.gov.
Instead of pausing until 2026, you can make 2025 a year of growth and positioning.
Quick Checklist for U65 Brokers
✅ Identify SBM states you’re licensed in.
✅ Complete certification using the links above.
✅ Educate clients about their options, even if you can’t enroll them on HealthCare.gov.
✅ Partner with Navigators for FFM enrollments until certification reopens.
✅ Prepare early for 2026 by setting aside time to complete training when it launches.
Call to Action
Need help navigating ACA certifications and compliance during this transition? Affordable Care Agents provides expert guidance, training resources, and support for brokers who want to stay ahead. Visit AffordableCareAgents.com for the latest updates.
CMS Disclaimer
“The Centers for Medicare & Medicaid Services (CMS) does not endorse any particular agent, broker, or organization. Assistance with Marketplace enrollment is available at no cost from certified Navigators and licensed agents/brokers who complete annual FFM training. This article is for educational purposes only and does not replace official CMS guidance.”
