2027 Marketplace Registration and Training for Agents and Brokers: MLMS Step-by-Step Guide

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Two agent training paths converging at a Marketplace registration completion checkpoint

Current status as of August 18, 2026: Plan Year 2027 Marketplace registration and training is not yet open. CMS says Plan Year 2026 registration is closed and the Marketplace Learning Management System, or MLMS, is offline while CMS performs maintenance and prepares for Plan Year 2027. CMS has not yet announced the opening date on its registration page.

When Plan Year 2027 registration opens, agents and brokers who completed Plan Year 2026 Individual Marketplace registration will be eligible for the shorter returning-agent training. Agents who are new to the Marketplace—or who did not complete Plan Year 2026 registration and training—will have to complete the full Individual Marketplace training. CMS says both versions will be available in English and Spanish.

Official CMS status page:
https://www.cms.gov/marketplace/agents-brokers/registration-training

Quick answer: How do agents complete 2027 Marketplace registration?

Once CMS opens Plan Year 2027 registration, an individual agent or broker generally must:

  1. Access the agent’s existing CMS Enterprise Portal account or create one if the agent has never had an account.
  2. Obtain the Federally-facilitated Marketplace agent/broker role and complete identity proofing if required.
  3. Review and update the agent’s MLMS profile.
  4. Enter and validate the correct individual National Producer Number, or NPN.
  5. Complete either the full 2027 Individual Marketplace training or the shorter returning-agent training.
  6. Execute every applicable Marketplace agreement.
  7. Save the training certificate.
  8. Confirm completion through the Marketplace Registration Tracker.
  9. Confirm that the agent’s NPN appears on the current Agent and Broker FFM Registration Completion List.

Do not stop after passing the training modules. Training is only one part of Marketplace registration. The agent must also complete the applicable agreements and verify that registration was successfully processed.

Federal regulations require an agent or broker to register with the Exchange before assisting qualified individuals with Marketplace enrollment, receive applicable training, comply with Exchange privacy and security standards, and comply with applicable state law. 45 C.F.R. § 155.220(d)–(e).

Official regulation:
https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-B/part-155/subpart-C/section-155.220

First, confirm that this is the correct registration process for your state

This guide primarily applies to agents and brokers using:

  • The Federally-facilitated Marketplace, or FFM;
  • HealthCare.gov; or
  • A State-based Marketplace that uses the federal platform for eligibility and enrollment, often called an SBM-FP.

A fully State-based Exchange may have its own certification, training, contracting, or registration process. CMS also notes that states can transition between Marketplace models, so an agent should not assume that last year’s process still applies.

Before beginning, verify the Marketplace platform used in each state where you intend to assist consumers:

https://www.cms.gov/marketplace/in-person-assisters/training-webinars/training/marketplaces-map

Completing federal MLMS training does not eliminate separate state licensing requirements, state Marketplace requirements, carrier appointment requirements, or agency contracting requirements.

What changed for Plan Year 2027?

HHS-approved vendor training is being discontinued

This is an important change for 2027.

Prior-year CMS instructions allowed agents to complete Marketplace training through the MLMS or through an HHS-approved training vendor. The 2027 Marketplace final rule discontinues the HHS-approved vendor training program. CMS states that agents and brokers will continue to have access to annual Exchange registration and training directly through CMS.

For Plan Year 2027, agents should therefore begin with the official CMS registration page and access training through the CMS Enterprise Portal and MLMS.

Do not rely on an older article, bookmarked third-party training page, or prior-year instructions that direct agents to an approved vendor. Those materials may accurately describe an earlier plan year but not the 2027 process.

Official 2027 final-rule summary:
https://www.cms.gov/newsroom/fact-sheets/hhs-notice-benefit-payment-parameters-2027-final-rule

CMS has separated agents into two training paths

Agent status2027 training requirement
Completed Plan Year 2026 Individual Marketplace registration and trainingEligible for the shorter returning-agent training and optional review modules
New to the Marketplace for 2027Must complete the full Individual Marketplace training
Previously participated but did not complete Plan Year 2026 registration and trainingMust complete the full Individual Marketplace training
Only participating in SHOPMust complete an MLMS profile and execute the SHOP Privacy and Security Agreement; CMS encourages SHOP training but does not require it

CMS controls the final classification within the MLMS. An agent should not select a course based merely on how many years the agent has sold ACA coverage. The important question is whether the agent completed Plan Year 2026 Individual Marketplace registration and training.

Before registration opens: complete this preflight checklist

Agents can prevent many last-minute registration problems by checking their credentials and licensing data before MLMS opens.

  • Locate the CMS Enterprise Portal User ID used in the prior plan year.
  • Reset the password if necessary instead of creating a duplicate account.
  • Confirm that multifactor authentication still works.
  • Confirm the agent’s individual NPN.
  • Confirm that the resident-state insurance license is active.
  • Confirm that the agent has an active, approved health-related line of authority.
  • Compare the agent’s legal first and last name in NIPR with the name used in the CMS account.
  • Confirm that the email address and telephone number in the CMS account are current.
  • Decide which business contact information should appear in public agent-search tools.
  • Confirm that the agent—not an assistant, agency principal, or coworker—controls the account and authentication method.
  • Create a secure folder in which to save the 2027 certificate and registration verification.

CMS uses NIPR information to evaluate an agent’s NPN, licensing status, and line of authority. CMS’s current NPN guidance says an agent generally needs an active state license and an active, approved health-related line of authority for the NPN to be treated as valid on the Registration Completion List.

NIPR producer lookup:
https://nipr.com/help/look-up-your-npn

Important: do not create a duplicate CMS account

Returning agents should use their existing CMS Enterprise Portal account. If an agent cannot remember the User ID or password, use the CMS recovery process rather than creating another account.

A duplicate account can separate the agent’s prior training record, identity information, NPN, or Marketplace role from the new account. It can also make troubleshooting more difficult immediately before Open Enrollment.

CMS says Marketplace agents use the CMS Enterprise Portal to access their profile and the MLMS. CMS also warns that an agent should log in at least once every 180 days or the account may be placed in a disabled status.

CMS Enterprise Portal:
https://portal.cms.gov/portal/

Instructions for returning Marketplace agents

A “returning agent” for 2027 is an agent or broker who completed Plan Year 2026 Individual Marketplace registration and training.

CMS has announced that qualifying returning agents will be eligible for shorter Plan Year 2027 training. CMS has not yet published its final 2027 click-by-click tip sheet, so some button names or screen layouts may change when the new plan year opens. The workflow below follows CMS’s current 2027 instructions and its latest detailed registration guide.

Step 1: Access the existing CMS Enterprise Portal account

Go to:

https://portal.cms.gov/portal/

Sign in using the same account used for Plan Year 2026.

Do not allow another person to log in under the agent’s User ID. CMS expressly instructs agents not to share their credentials, passwords, or multifactor-authentication information. Each agent should use and control the agent’s own FFM User ID.

Step 2: Open the Marketplace agent and broker training area

After signing in:

  1. Locate the Marketplace Training – Agent Broker tile.
  2. Open the tile to display the available links.
  3. Select the MLMS Training link.
  4. Confirm that the appropriate agent/broker role is selected.

If the Marketplace tile is missing, do not immediately create a new account. First check whether the Marketplace role must be restored or added to the existing account.

Step 3: review and update the MLMS profile

Review every field rather than clicking through the prior-year information.

Pay particular attention to:

  • Individual NPN;
  • Legal first and last name;
  • Business name;
  • Business address;
  • Public telephone number;
  • Public email address;
  • States served;
  • Website address;
  • Preferred contact information; and
  • The selected MLMS user role.

CMS states that profile information may be used to populate Find Local Help and Help On Demand. An old telephone number or email address can therefore become more than an internal profile error—it can prevent a prospective client from reaching the agent.

Step 4: complete the shorter returning-agent training

Agents who completed Plan Year 2026 registration should be placed into the shorter Plan Year 2027 training when it becomes available.

CMS also says returning agents may have access to optional review modules. An experienced agent may still choose to complete additional training, but the shorter curriculum is the required path CMS has announced for qualifying returning agents.

CMS has previously stated that the shorter training may be completed in as little as approximately 30 minutes. Actual completion time will depend on the agent, the modules assigned for 2027, and whether optional material is reviewed.

Practical recommendation: Do not schedule the training in the few minutes before a client appointment. Leave time for an account problem, an NPN error, a required agreement, or a processing delay.

Step 5: execute all applicable Marketplace agreements

Passing the training does not complete registration by itself.

After training:

  1. Return to the MLMS landing page.
  2. Open each applicable Marketplace agreement.
  3. Read the agreement.
  4. Select I Agree or the corresponding acceptance button.
  5. Confirm that no agreement remains pending.

CMS’s latest detailed guidance instructs agents to launch, read, and agree to all applicable agreements after updating the profile and completing the training.

Step 6: save the Plan Year 2027 certificate

From the MLMS landing page:

  1. Open Your Transcript.
  2. Locate the completed 2027 course.
  3. Select View Certificate(s).
  4. Save the certificate as a PDF.
  5. Use a filename that includes the agent’s name, NPN, and plan year.

Example:

2027-Marketplace-Certificate-Jane-Smith-NPN-1234567.pdf

Store the certificate somewhere the agent or agency can retrieve it later. Do not rely on a browser download folder or a screenshot as the only copy.

Step 7: verify completion outside the training screen

After completing the profile, training, and agreements, verify the result using the Registration Tracker and Registration Completion List. Do not assume the process is complete simply because the final training module shows a passing score.

The verification steps are explained later in this guide.

Instructions for new or lapsed Marketplace agents

For Plan Year 2027, CMS places the following agents in the full-training path:

  • Agents who are new to the Marketplace; and
  • Agents who did not complete Plan Year 2026 Individual Marketplace registration and training.

CMS has not yet published its final 2027 new-agent tip sheet. The steps below use the current 2027 CMS announcement together with CMS’s latest detailed new-agent instructions. Screen labels may be adjusted when the 2027 system opens.

Step 1: create a CMS Enterprise Portal account only when necessary

Go to:

https://portal.cms.gov/portal/

Select New User Registration only when the agent does not already have a CMS Enterprise Portal account.

During the prior-year process, CMS directed new agents to select:

Federally Facilitated Marketplace (FFM)/Request for Marketplace Learning Management System (MLMS) Training Access

Follow the prompts and use an email address the agent will continue to control.

An agent who already has a CMS Enterprise Portal account—even from a prior year—should recover and use the existing account rather than create a second one.

Step 2: request the FFM agent/broker role

After signing in:

  1. Go to My Portal.
  2. Select Add Application.
  3. Open the Application Catalog.
  4. Search for “Fed” or “Fe.”
  5. Select the FFM option that requests MLMS training access.
  6. Follow the prompts to request the agent/broker role.

The precise label may be updated for 2027, so follow the current on-screen CMS instructions.

Step 3: complete remote identity proofing

CMS may require the agent to complete electronic identity verification.

The process may ask the agent to:

  • Confirm personal information;
  • Answer identity-verification questions;
  • Log out and back into the portal; or
  • Contact CMS’s identity-proofing vendor using a telephone number and confirmation code supplied by the portal.

CMS’s latest new-agent instructions identify Experian as its identity-proofing vendor. Agents who previously completed CMS identity proofing may not be required to repeat it.

Use only the telephone number or instructions displayed by the official CMS portal. Do not provide identifying information to a number found in an advertisement, unsolicited email, or unofficial search result.

Step 4: complete the MLMS profile

From the CMS Enterprise Portal:

  1. Open the Marketplace Training – Agent Broker tile.
  2. Select MLMS Training.
  3. Select the appropriate agent/broker role.
  4. Complete all required profile fields.
  5. Carefully enter the agent’s individual NPN.
  6. Review the public business and contact information.
  7. Select Save/Update.
  8. Continue until the profile displays as complete.

CMS warns that individual, business-entity, and web-based-entity NPNs are different. Entering an individual NPN into the wrong profile field can interfere with credit or compensation for Marketplace enrollments.

Step 5: complete the full Individual Marketplace training

New and lapsed agents must complete the full Plan Year 2027 Individual Marketplace curriculum through MLMS once CMS makes it available.

Because CMS is discontinuing the approved-vendor training program for 2027, agents should access the training through the CMS Enterprise Portal and MLMS rather than relying on a separate third-party training site.

Complete every required module and examination. Before leaving the system, confirm that the transcript shows the course as completed.

Step 6: execute every applicable agreement

After completing the training:

  1. Return to the MLMS landing page.
  2. Open the applicable Marketplace agreement or agreements.
  3. Read each agreement.
  4. Select the acceptance button.
  5. Confirm that the agreement status is complete.

An agent who finishes training but does not execute the applicable agreements has not finished the registration process. CMS’s detailed workflow treats execution of the agreements as a separate required step.

Step 7: save the certificate and verify registration

Download the Plan Year 2027 certificate from the agent’s MLMS transcript.

Then use the Registration Tracker and Registration Completion List to confirm that the agent’s registration has processed successfully.

How to confirm that 2027 Marketplace registration is actually complete

A practical registration file should contain more than a training certificate.

Check each of the following:

Verification pointWhat to confirmWhat to save
MLMS transcriptRequired 2027 training shows completedPDF or screenshot
Marketplace agreementEvery applicable agreement shows acceptedPDF or screenshot if available
Training certificateCertificate identifies the correct agent and plan yearCertificate PDF
Registration TrackerAll required registration steps show completeDated screenshot or PDF
Registration Completion ListCorrect individual NPN appears for the current plan yearDated search result
Find Local HelpPublic information is accurate, if the agent is listedDated screenshot
Help On DemandAgent remains eligible and profile information is current, if participatingProfile confirmation

1. Check the Marketplace Registration Tracker

Agent and Broker Marketplace Registration Tracker:

https://data.healthcare.gov/ab-registration-tracker/

Use the Tracker to determine whether CMS has credited all required registration steps.

If a training module is complete but an agreement is missing, return to MLMS and finish the agreement. If the Tracker does not recognize the training, confirm that the agent used the correct CMS account and NPN.

2. Check the Registration Completion List

Agent and Broker FFM Registration Completion List:

Open the Agent and Broker FFM Registration Completion List

Search using the agent’s individual NPN.

CMS describes the RCL as the list of NPNs for agents and brokers who have completed Marketplace registration for the current year. CMS says the list may be posted as frequently as daily. CMS separately cautions that NPN and state-license information should be validated against state or NAIC records.

The RCL confirms CMS Marketplace registration. It does not replace:

  • State insurance licensing;
  • An active health-related line of authority;
  • Carrier appointment;
  • Agency contracting;
  • Required exchange registration in a fully State-based Marketplace; or
  • Any carrier-specific readiness or certification requirement.

3. Allow time for CMS systems to update

CMS has not yet posted 2027-specific processing-time instructions. In its latest detailed agent guides, CMS advised that:

  • The Registration Tracker may take one to two business days to update;
  • The RCL may take one to two business days to update; and
  • Find Local Help may take up to three business days to update.

Treat those figures as planning estimates until CMS publishes the 2027 tip sheets.

Practical rule: Complete registration early enough to allow time for processing and correction. Do not wait until the day an enrollment must be submitted.

NPN validation: the most important information to check

The NPN is the unique identifier assigned through the insurance producer licensing process. CMS uses NPN and NIPR data to associate the agent’s Marketplace registration with the agent’s state licensing record.

The following information should match

CMS’s current NPN FAQ says these items should match between NIPR and MLMS:

  • Legal first name;
  • Legal last name; and
  • Individual NPN.

CMS also states that the agent’s Social Security number must be included in the secure MLMS profile for identity and NPN name-match validation. Do not send a Social Security number to CMS by ordinary email. Enter it only through the secure CMS process when requested.

Check the individual NPN, not just an agency NPN

An agency may have a business-entity NPN in addition to each agent’s individual NPN. Do not substitute the agency’s NPN for the individual agent’s NPN in the individual profile.

Before saving the profile, confirm:

  • Whose profile is open;
  • Whether the field requests an individual or business NPN;
  • Whether the NPN belongs to the agent completing the training; and
  • Whether the name displayed matches the NIPR record.

Confirm the license and line of authority

CMS’s linked NPN guidance says a valid NPN on the RCL generally requires:

  1. An active state license;
  2. A health-related line of authority approved by the applicable state; and
  3. An active status for that line of authority.

A correct NPN will not cure an expired license or inactive line of authority.

What to do when the NPN will not validate

Use this order:

  1. Verify the NPN through NIPR.
  2. Compare the legal name in NIPR with the name in MLMS.
  3. Confirm that the resident-state license is active.
  4. Confirm that the health-related line of authority is active.
  5. Confirm that the NPN is entered in the correct individual field.
  6. Correct inaccurate licensing information through the applicable state or NIPR process.
  7. Allow time for corrected licensing data to reach CMS.
  8. Contact the FFM Agent/Broker Email Help Desk if the information is accurate but CMS still does not validate it.

Email:

[email protected]

Do not include a Social Security number, full consumer application, tax documents, or other unnecessary personally identifiable information in the email.

Find Local Help and Help On Demand

Find Local Help

Find Local Help allows consumers to search for local individuals and organizations that can assist with Marketplace coverage.

https://www.healthcare.gov/find-local-help/

Because CMS may use MLMS profile information in public search tools, review the profile as a consumer would see it:

  • Is the telephone number answered?
  • Is the email address monitored?
  • Is the agency name spelled correctly?
  • Is the website current?
  • Are the service areas accurate?
  • Does the profile use a professional business address where appropriate?

Help On Demand

Help On Demand connects consumers seeking assistance with Marketplace-registered, state-licensed agents and brokers in their area. CMS states that only agents and brokers who have completed Marketplace training and registration are eligible to participate.

CMS Help On Demand information:

https://www.cms.gov/marketplace/agents-brokers/help-on-demand

Completing Marketplace registration does not necessarily enroll an agent in Help On Demand automatically. Agents interested in the service should review its separate registration, profile, availability, and referral-response requirements.

SHOP registration is different

Agents participating only in the Small Business Health Options Program should not assume that the Individual Marketplace training requirements apply in exactly the same way.

CMS states that a SHOP agent or broker must:

  • Complete an MLMS profile; and
  • Execute the SHOP Privacy and Security Agreement.

CMS strongly encourages the related SHOP training but does not currently require it.

An agent working in both the Individual Marketplace and SHOP should complete the requirements applicable to both activities.

Registration troubleshooting guide

ProblemLikely issueRecommended action
CMS account is disabledThe agent has not logged in recentlyUse the CMS account-recovery process or contact the Marketplace Service Desk
Agent forgot the User ID or passwordExisting account cannot be accessedRecover the existing account; do not create a duplicate
Marketplace Training tile is missingFFM role may be absent from the accountUse Add Application to request or restore FFM/MLMS access
Electronic identity proofing failsCMS cannot verify the supplied information electronicallyFollow the telephone and confirmation-code instructions displayed by the CMS portal
Agent receives an NPN validation errorName, NPN, SSN, license, or line-of-authority data may not matchCompare MLMS with NIPR and state licensing records
Training shows complete but registration is not completeAgreement may not have been executedReturn to MLMS and review all applicable agreements
Certificate is available but NPN is not on RCLProcessing delay or NPN/licensing issueCheck the Tracker, wait the published processing period, then contact the Agent/Broker Email Help Desk
Find Local Help displays old informationMLMS profile contains old information or the public listing has not updatedCorrect the MLMS profile and allow processing time
Agent used the wrong NPNIndividual and agency profiles were confusedCorrect the MLMS profile and verify the individual NPN
Agent completed prior-year trainingWrong plan yearConfirm the transcript and certificate identify Plan Year 2027
Consumer-specific enrollment problemThe issue concerns a specific Marketplace applicationContact the Marketplace Call Center Agent/Broker Line using the agent’s NPN
MLMS will not load or a course will not record completionTechnical MLMS problemContact the MLMS Help Desk and preserve screenshots of the error

Which CMS help desk should an agent contact?

CMS Enterprise Portal, password, account, or identity-proofing problems

Marketplace Service Desk

Telephone:
1-855-CMS-1515
1-855-267-1515

CMS identifies this desk for Enterprise Portal password resets, account lockouts, identity-proofing issues, general registration questions, and certain MLMS technical problems.

RCL, Find Local Help, Help On Demand, or escalated registration problems

Agent/Broker Email Help Desk

Email:
[email protected]

CMS identifies this email desk for Registration Completion List issues, Find Local Help questions, Help On Demand questions, and escalated registration and training matters.

MLMS course or training-system problems

Agent/Broker Training and Registration Email Help Desk

Email:
[email protected]

CMS identifies this desk for technical or system-specific MLMS problems and questions about accessing training and examinations.

Consumer-specific Marketplace application issues

Marketplace Call Center Agent/Broker Line

Telephone:
1-855-788-6275

CMS instructs agents to enter their NPN to access this line. It is intended for consumer-specific Marketplace eligibility, enrollment, account, and application issues.

Information to preserve before contacting a help desk

Prepare:

  • Agent’s full name;
  • Individual NPN;
  • CMS User ID, when appropriate;
  • Plan year;
  • Date and approximate time of the error;
  • Exact error message;
  • Screenshot of the error;
  • Browser and device used;
  • Registration step that failed;
  • Steps already attempted; and
  • A safe callback number or email address.

Do not send passwords, multifactor-authentication codes, Social Security numbers, tax documents, or unnecessary consumer PII by email.

Official CMS help-desk directory:
https://www.cms.gov/marketplace/agents-brokers/files/agent-broker-help-desks.pdf

A practical registration workflow for agencies

An agency should not rely on agents saying, “I completed my certification.”

Use a registration roster containing:

FieldExample
Agent nameJane Smith
Individual NPN1234567
Resident stateArizona
License verifiedYes — August 20, 2026
Health LOA verifiedYes
New or returningReturning
MLMS profile updatedAugust 21, 2026
Training completedAugust 21, 2026
Agreements executedAugust 21, 2026
Certificate receivedYes
Tracker verifiedAugust 22, 2026
RCL verifiedAugust 23, 2026
Find Local Help checkedAugust 25, 2026
Carrier appointments confirmedYes
Follow-up neededNone
  • Require a copy of each agent’s certificate.
  • Verify each individual NPN on the RCL.
  • Do not accept an agency NPN in place of an individual NPN.
  • Recheck state-license and line-of-authority status.
  • Keep carrier appointments separate from CMS registration status.
  • Do not ask agents to share passwords or authentication codes.
  • Have each agent personally access and accept the applicable agreements.
  • Assign one person to review the agency roster without logging into agents’ accounts.
  • Recheck incomplete agents before they begin Marketplace assistance.
  • Maintain a dated record of the verification.

This process does not create a CMS requirement that an agency maintain this exact spreadsheet. It is a practical internal control that helps distinguish “training started” from “registration verified.”

Common registration mistakes

Mistake 1: treating the training certificate as the entire process

The training certificate is important, but it does not replace profile completion, applicable agreements, NPN validation, or final registration verification.

Mistake 2: using a prior-year certificate

Marketplace registration is plan-year specific. Make sure the transcript and certificate identify Plan Year 2027.

Mistake 3: creating a second CMS account

Recover the original account whenever possible. Duplicate accounts can separate Marketplace roles and prior training history.

Mistake 4: entering the agency’s NPN in the individual-agent field

Verify every NPN before saving the profile. CMS treats individual, business-entity, and web-based-entity profiles separately.

Mistake 5: waiting until the first enrollment

Registration problems are easier to solve before a consumer is waiting. Allow time for the Tracker, RCL, licensing data, and public directories to update.

Mistake 6: failing to accept an agreement

An agent can pass the course and still leave registration incomplete by overlooking an applicable Marketplace agreement.

Mistake 7: assuming CMS registration establishes carrier appointment

CMS registration, state licensing, carrier appointment, agency contracting, and State-based Exchange requirements are related but separate.

Mistake 8: using old vendor-training instructions

The HHS-approved vendor training program is being discontinued for 2027. Start from the official CMS registration page and use the CMS-directed MLMS process.

Mistake 9: publishing personal contact information unintentionally

Review fields that may populate Find Local Help or Help On Demand. Use appropriate business contact information and make sure it is monitored.

Mistake 10: sharing an account within the agency

CMS instructs each agent to use the agent’s own FFM User ID and not share credentials, passwords, or MFA information.

Frequently asked questions

Is 2027 Marketplace agent registration open?

Not as of August 18, 2026. CMS says Plan Year 2026 registration is closed and MLMS is offline while CMS performs maintenance and prepares for Plan Year 2027 registration and training. Check the official CMS page for the opening announcement.

https://www.cms.gov/marketplace/agents-brokers/registration-training

Is “FFM certification” the same as Marketplace registration and training?

Agents frequently use the phrase “FFM certification.” CMS generally describes the official process as annual Marketplace registration and training. It includes more than passing a course: the agent must complete the profile, training, applicable agreements, and final registration steps.

Do Marketplace agents have to complete training every year?

Yes. CMS describes Marketplace registration and training as an annual process. For 2027, agents who completed Plan Year 2026 Individual Marketplace registration are eligible for shorter returning-agent training. Agents who did not complete 2026 must take the full training.

Who qualifies for the shorter 2027 training?

Agents and brokers who completed Plan Year 2026 Individual Marketplace registration and training qualify for the shorter 2027 training and optional review modules. Merely having a CMS account, NPN, license, or earlier Marketplace experience does not by itself satisfy that standard.

Can an agent use third-party vendor training for 2027?

The 2027 final rule discontinues the HHS-approved vendor training program. CMS says agents and brokers will continue to complete annual Exchange registration and training directly through CMS. Follow the CMS Enterprise Portal and MLMS instructions for 2027.

Can an agent assist Marketplace consumers immediately after passing the course?

Do not rely only on a passing training score. Complete the applicable agreements and verify registration through the CMS Tracker and current RCL. The governing regulation requires registration in advance of assisting qualified individuals with Exchange enrollment.

How can an agent prove that 2027 registration was completed?

Keep:

  • The 2027 training certificate;
  • Confirmation that applicable agreements were accepted;
  • A completed Registration Tracker result; and
  • Confirmation that the individual NPN appears on the current RCL.

How long does it take for an NPN to appear on the RCL?

CMS has not yet published a 2027-specific processing time. The latest detailed CMS guides say the Tracker and RCL may take one to two business days to update. Treat that as an estimate until the 2027 instructions are published.

Why is an NPN not validating?

Common reasons include:

  • The name in MLMS does not exactly match NIPR;
  • The wrong NPN was entered;
  • The agent entered a business NPN instead of an individual NPN;
  • The state license is inactive;
  • The health-related line of authority is inactive or not approved;
  • Required identity information is incomplete; or
  • Recently corrected licensing information has not yet reached CMS.

CMS’s linked NPN FAQ says the agent’s first name, last name, and NPN must match between NIPR and MLMS.

Does appearing on the RCL guarantee that a carrier will pay commissions?

No. The RCL verifies current Marketplace registration status associated with the NPN. State licensing, line of authority, carrier appointment, producer agreement, writing-number assignment, and carrier compensation rules remain separate.

Does completing registration automatically place an agent in Help On Demand?

No. Marketplace registration is an eligibility requirement for Help On Demand, but the agent must review and complete the service’s separate participation process. CMS limits Help On Demand participation to Marketplace-registered, state-licensed agents and brokers.

Is SHOP training mandatory?

CMS currently requires an MLMS profile and execution of the SHOP Privacy and Security Agreement. CMS strongly encourages the SHOP training but does not require it.

No. CMS finalized a requirement for agents, brokers, and web-brokers to use the HHS-approved standardized form for enrollments for plan years beginning on or after January 1, 2028. That is separate from Plan Year 2027 registration and training. Agents must still comply with the consumer-consent and application-review documentation requirements applicable to their 2027 activities.

Read the 2027 ACA Marketplace Final Rule for Agents for the other changes that affect agent workflows.

Can an agency complete registration for all its agents using one login?

Each individual agent should use the agent’s own CMS User ID, control the account, complete assigned training, and accept applicable agreements. CMS says credentials, passwords, and MFA information must not be shared.

Does federal Marketplace registration apply in every state?

No. Fully State-based Exchanges may maintain their own training and registration processes. Agents should verify each state’s Marketplace model and follow the applicable exchange’s instructions.

Final 2027 Marketplace registration checklist

  • Confirm whether the state uses the FFM, an SBM-FP, or a fully State-based Exchange.
  • Confirm whether the agent is classified as new or returning.
  • Recover the existing CMS Enterprise Portal account.
  • Confirm that the portal account and multifactor authentication work.
  • Confirm the individual NPN.
  • Confirm the resident-state license is active.
  • Confirm the health-related line of authority is active.
  • Compare the agent’s legal name in NIPR and MLMS.
  • Request or restore the FFM agent/broker role if necessary.
  • Complete identity proofing if required.
  • Review and update the MLMS profile.
  • Review public business contact information.
  • Complete the correct Plan Year 2027 training curriculum.
  • Confirm that every module and examination is complete.
  • Execute every applicable Marketplace agreement.
  • Save the Plan Year 2027 certificate.
  • Check the Registration Tracker.
  • Confirm the individual NPN on the current RCL.
  • Review Find Local Help information.
  • Complete or update Help On Demand participation, if applicable.
  • Confirm state-exchange requirements, carrier appointments, and agency contracting.
  • Store the certificate and verification records in a retrievable location.
  • Do not share CMS credentials or authentication codes.

Registration is only the beginning of an ACA workflow

Marketplace registration authorizes an agent to participate through the applicable Marketplace process. It does not by itself organize the records created while assisting each consumer.

Agents may also need a reliable process for:

  • Documenting the consumer’s authorization;
  • Recording the consumer’s review and confirmation of application information;
  • Tracking eligibility and document issues;
  • Preserving supporting records;
  • Following up on unresolved application items; and
  • Maintaining a clear history of the assistance provided.

Informed Choice helps agents organize ACA authorization, application-review, eligibility-review, and follow-up records in one workspace. It does not replace HealthCare.gov, a State-based Exchange, a carrier, or an approved enrollment platform.

Learn about the ACA Agent Workspace.

Review the ACA Marketplace Consent and Application Review Requirements.

Use the ACA Special Enrollment Period Guide for SEP documentation and workflow planning.

Official sources

CMS Marketplace registration and training:
https://www.cms.gov/marketplace/agents-brokers/registration-training

CMS Enterprise Portal:
https://portal.cms.gov/portal/

Agent and Broker Marketplace Registration Tracker:
https://data.healthcare.gov/ab-registration-tracker/

FFM Registration Completion List:
Open the Agent and Broker FFM Registration Completion List

CMS state Marketplace models:
https://www.cms.gov/marketplace/in-person-assisters/training-webinars/training/marketplaces-map

45 C.F.R. § 155.220:
https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-B/part-155/subpart-C/section-155.220

CMS NPN Validation FAQ:
https://www.cms.gov/marketplace/agents-brokers/files/national-producer-number-validation-frequently-asked-questions.pdf

CMS agent and broker help desks:
https://www.cms.gov/marketplace/agents-brokers/files/agent-broker-help-desks.pdf

CMS Help On Demand:
https://www.cms.gov/marketplace/agents-brokers/help-on-demand

2027 Marketplace final-rule summary:
https://www.cms.gov/newsroom/fact-sheets/hhs-notice-benefit-payment-parameters-2027-final-rule


This article provides general operational information for insurance professionals. CMS, state Marketplace, licensing, and carrier requirements can change. Agents and agencies should verify current requirements through the applicable government agency, Marketplace, carrier, and legal or compliance advisers.

Christian Rodgers

Medicare and ACA Compliance Expert

Christian Rodgers is a Medicare and ACA compliance expert with over 30 years in the healthcare industry, having worked for some of the largest health plans in the United States. He has provided Medicare sales training to hundreds of agents in California and Florida.

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