FFM Registration for Agents: Plan Year 2027 Steps

FFM registration for agents is the yearly process of creating or renewing your CMS account, passing identity proofing, setting up your registration profile, completing Marketplace training, and signing the Exchange agreements for the plan year. For Plan Year 2027, agents who completed Plan Year 2026 registration can finish now through a shorter training in the Marketplace Learning Management System (MLMS). Agents without Plan Year 2026 Exchange agreements can't complete registration with the Federally-facilitated Exchanges (FFE and SBE-FPs) until February 1, 2027, under a temporary moratorium that CMS can lift, extend, or change.

This guide covers the returning-agent steps from CMS's PY2027 tipsheet, the identity re-proofing requirement, how to confirm your registration went through, and what happens if it lapses.

Key takeaways

• PY2027 registration and training is live in the MLMS for returning agents, in English and Spanish. You're returning if you completed PY2026 Individual Marketplace registration and training.
• All existing agents must re-identity proof through Login.gov or ID.me and link that sign-in to their existing CMS Enterprise Portal (IDM) account. If you skip the linking step, you can't get the training role or reach the MLMS.
• A moratorium that took effect September 22, 2026 stops agents without PY2026 Exchange agreements from completing FFE and SBE-FP registration for PY2027 until February 1, 2027, unless CMS changes that date. February 1 comes after Open Enrollment ends on January 15, 2027.
• Exchange agreements generally last one year and end automatically before the next Open Enrollment, so you have to register again every year.
• HHS-approved vendor training has ended. You train directly with CMS. The training is free and gives no CEUs.
• After you finish, allow 1 to 2 business days for the Registration Tracker and the Registration Completion List (RCL), and up to 3 for Find Local Help. Then save your certificate and the proof that you're listed.

Is Plan Year 2027 FFM training open yet?

Yes, for returning agents. CMS states that Plan Year 2027 registration and training is live for returning agents and brokers on the MLMS, in English and Spanish. As of this writing, the New Agents and Brokers section of the same page says only "Information will be available soon." CMS uses that section for agents who did not complete Plan Year 2026 training.

If you help consumers enroll through the Marketplace or apply for APTC and CSRs, you have to register. Under 45 CFR 155.220(d), an agent who enrolls consumers through the Exchange must register with the Exchange before assisting, receive training, and comply with the Exchange's privacy and security standards. Under 155.220(j)(1), an agent assisting with FFE enrollment must have signed the required 155.260(b) agreement, be registered with the FFEs, and follow the standards of conduct.

Who counts as a returning agent for Plan Year 2027?

You're a returning agent if you completed Plan Year 2026 Individual Marketplace registration and training. That includes agents whose first year was 2026. Returning agents take a shorter PY2027 training and can add optional review modules.

If you skipped 2026, CMS's page groups you with new agents, meaning agents who did not complete PY2026 training. The moratorium covers agents without PY2026 Exchange agreements, and the IFC's wording doesn't make an exception for agents who registered in earlier years. Before you plan your season around your status, confirm it with the FFM help desk.

What does the new-agent moratorium mean for 2027?

An interim final rule with comment period, CMS-9872-IFC (91 FR 60317), was published September 23, 2026 and took effect September 22, 2026. It put a temporary moratorium in place: agents and brokers without Plan Year 2026 Exchange agreements cannot complete registration with the Federally-facilitated Exchanges for Plan Year 2027 until February 1, 2027. Until the moratorium is lifted, they also can't complete training or sign the Exchange agreements.

Where the moratorium applies

• It covers the FFE and State-based Exchanges on the Federal platform (SBE-FPs).
• It does not affect registration with State-based Exchanges (SBEs).
• It does not apply to web-broker registration with the FFEs.

How long it lasts

The moratorium runs until February 1, 2027, unless CMS lifts it early, extends it, or otherwise changes it through a later Federal Register notice. The IFC says PY2027 Open Enrollment begins November 1, 2026, and HealthCare.gov lists January 15 as the last day of Open Enrollment. Unless CMS lifts the moratorium early, an affected agent can't complete FFE registration at any point during PY2027 Open Enrollment.

The reinstatement exception

The moratorium doesn't block agents whose termination under 45 CFR 155.220(g) or denial under 155.220(k)(1)(i) is reversed, or whose agreements are reinstated, while the moratorium is in place.

Commenting on the rule

Comments on file code CMS-9872-IFC are due by November 21, 2026.

If the moratorium affects you, talk with your upline about which work you can do this season. Check the CMS Registration and Training page and the Federal Register for any notice that changes the February 1 date.

Do you have to redo identity proofing with Login.gov or ID.me?

Yes. CMS's September 22, 2026 anti-fraud fact sheet says all existing agents and brokers must now re-identity proof through either Login.gov or ID.me. You need only one of the two, and identity proofing happens while you create the account.

Creating the credential is only half of the job. You also have to link it to your existing CMS Enterprise Portal IDM account. The PY2027 tipsheet says agents who skip linking are blocked from the training role and from the MLMS. If you can't get the Agent Broker Training Access role, check this first.

How do you complete PY2027 FFM registration as a returning agent?

Before you start, make sure your existing IDM password works. HealthCare.gov's agent quick-start tells agents who already have a CMS Enterprise Portal account to renew it, not create another one. That page's renewal link still points to a Plan Year 2025 guide, and its tile names differ from the PY2027 tipsheet. Follow the tipsheet.

Here are the tipsheet's steps in order:

1. Create Login.gov or ID.me credentials if you don't already have them. You need only one, and identity proofing happens during account creation. If you've used Login.gov or ID.me before, skip to linking.
2. Link the new sign-in to your IDM account. Choose "Start linking new sign-in option," then sign in with your IDM User ID.
3. Request training access. Under "Select an Application," search "Fed." Choose the "Federally Facilitated Marketplace (FFM)/Request for MLMS Training Access" tile, accept the terms, and select the "Agent Broker Training Access" role.
4. Complete your MLMS profile. Open the "Marketplace Training – Agent Broker" tile. Choose the Agent Broker role. CMS says to select Non Agent Broker only if you don't intend to help consumers enroll in Marketplace coverage. Then set your display preferences for Find Local Help and Help On Demand.
5. Finish the condensed returning curriculum. The MLMS enrolls returning agents automatically, and the curriculum shows as "Active" under "View Your Transcript." Finish all required courseware, including the exams. You can add optional modules such as SHOP.
6. Sign the agreements. Open and read each required agreement, then select "I Agree."
7. Print your certificate. Go to Your Transcript > Completed > "View Completion Page" and print the Plan Year 2027 certificate.

Only agents who have completed Marketplace training and registration can participate in Help On Demand. It's the CMS-contracted service that connects consumers with Marketplace-registered, state-licensed agents.

Common FFM registration mistakes

• Putting your individual NPN in a business field. CMS warns against entering an individual NPN in the business or web-based entity field of the MLMS profile. If your NPN is wrong, or copied into those fields, an issuer may deny you compensation or credit.
• Skipping the link step. If your Login.gov or ID.me credential isn't linked to your IDM account, you can't get the training role.
• Opening a second Portal account. Renew the account you already have.
• Sharing your sign-in. CMS says never to share your credentials, passwords, or MFA details with anyone. Only you should use your FFM User ID, and that includes keeping it from assistants and upline staff.
• Stopping after the exams. Under the IFC, registration includes signing the Exchange agreements. Training alone doesn't complete it.
• Following an outdated guide. Old pages describe earlier plan years and different tile names.

How do you check that your NPN is on the Registration Completion List?

Your registration can take 1 to 2 business days to show on the Agent and Broker Marketplace Registration Tracker and on the RCL. It can take up to 3 business days to show on Find Local Help.

The RCL lists the NPNs of agents and brokers who completed Marketplace registration for the current year. CMS posts it as often as daily. Agents report their own NPNs, so CMS says to check them against state or NAIC records to confirm licensure. Agency owners checking a new hire should do the same.

If your NPN is still missing from the PY2027 RCL after that window, email FFMProducer-AssisterHelpDesk@cms.hhs.gov. Here's a short template you can adapt:

Subject: NPN missing from PY2027 Registration Completion List

My name is [full name], NPN [number]. I completed Plan Year 2027 Marketplace training and signed the agreements on [date]. My NPN does not appear on the RCL as of [date]. I've attached my PY2027 completion certificate. Please let me know what else you need.

Can you still take FFM training through a vendor, and does it earn CE?

No to both. The 2027 Payment Notice final rule, effective July 20, 2026, removed 45 CFR 155.222. That ended the program of HHS-approved vendors for annual agent and broker training. You now complete annual Exchange training and registration directly with CMS, so don't count a third-party course as your FFM registration.

HealthCare.gov says the free CMS training doesn't offer continuing education units (CEUs). Plan your state CE separately.

What licensing does FFM registration require?

CMS says agents without an approved health-related Line of Authority (LOA), as determined by their resident state, don't have access to Marketplace systems and may not help consumers enroll through the Marketplace.

Your license has to stay current after you register. Under 45 CFR 155.220, HHS may terminate your FFE agreement immediately for cause if you fail to keep the required state license in every state where you actively assist consumers. For that kind of termination, you may ask the CMS Administrator for reconsideration within 30 calendar days of the written notice.

What happens if your registration lapses or your agreement is terminated?

According to the IFC, agents generally sign 1-year Exchange agreements. Each agreement takes effect at the start of that plan year's Open Enrollment and ends automatically before the next plan year's Open Enrollment Period. Registration doesn't roll over from year to year, so you have to complete it every year.

Once your FFE agreement is terminated, you're no longer registered with the FFEs. Under 155.220, you may not help with enrollment through an FFE or with APTC and CSR applications. You must keep protecting the PII you accessed under the agreements.

CMS also publishes the Agent and Broker FFM Registration Termination List (RTL), which lists the NPNs whose FFM agreements and registration CMS has terminated. Termination is governed by 45 CFR 155.220(f) through (g). Agency owners should check new hires against the RTL as well as the RCL.

Do you need FFM registration in a State-based Exchange state?

The steps in this guide are for the FFEs and SBE-FPs. The moratorium doesn't affect registration with State-based Exchanges. If you hold licenses in SBE states, ask each exchange what it requires.

What do you need to sell only SHOP plans?

To participate in SHOP, you must complete an MLMS profile and sign the SHOP Privacy and Security Agreement. CMS strongly encourages the SHOP training but doesn't require it. Returning agents can add SHOP as an optional module in the MLMS.

Plan Year 2027 registration timeline

The Open Enrollment dates come from HealthCare.gov's dates and deadlines page. If you're a returning agent, plan to show on the RCL before November 1 so you aren't waiting on the 1-to-3-business-day lag during your first week of Open Enrollment.

How does registration connect to the rest of the sale?

Registration ties into several other requirements that affect your sale.

• Carrier credit. An inaccurate NPN in your MLMS profile can lead an issuer to deny compensation or credit. Ask each carrier or your upline how they want proof of PY2027 registration.
• Electronic consumer authorization. CMS's anti-fraud fact sheet says CMS will require electronic consumer authorization before Open Enrollment, before an agent or broker can take any action on an application or enrollment.
• SSNs and immigration documents. The same fact sheet says every application involving an agent must include verifiable SSNs or immigration document numbers for all applicants except newborns.
• Consumer-completed applications. The fact sheet says CMS now prohibits agents and brokers from being added to applications that consumers should be completing on their own through HealthCare.gov.
• The 2028 consent form. For enrollments for plan years beginning on or after January 1, 2028, the 2027 Payment Notice requires agents, brokers, and web-brokers to use the HHS-created form for eligibility application review and consumer consent documentation.

Our guide to ACA agent consent documentation requirements covers what those records must contain.

What to document and keep

Here's a checklist to keep with your other licensing records:

• Your PY2027 completion certificate, saved as a PDF
• A dated screenshot of your NPN on the RCL and on the Registration Tracker
• The dates you linked your Login.gov or ID.me credential, finished training, and signed the agreements
• A printout from your state or NAIC records showing your health-related LOA
• Every email to and from a CMS help desk

The sources in this guide don't set a retention period for these records. Ask your carriers and upline how long they expect you to keep them.

Working Open Enrollment in LeadGPT after you register

Once you show on the RCL, LeadGPT can help you keep Open Enrollment files organized. You can attach signed consent forms to each lead record and track consent dates in custom data fields. Calls you make or answer in LeadGPT are recorded and get transcripts and AI summaries in the Call Log, so check with your compliance team and carriers on call-recording disclosure rules in the states you work. Sofia can set your follow-up reminders. See the features overview or take the interactive demo.

Where to get help and what to do next

CMS lists these contacts:

• FFM registration and policy questions: FFMProducer-AssisterHelpDesk@cms.hhs.gov
• CMS Enterprise Portal login help: CMS_FEPS@cms.hhs.gov or 1-855-CMS-1515
• MLMS questions: MLMSHelpDesk@cms.hhs.gov

Next steps:

1. Test your IDM password, create your Login.gov or ID.me credential, and link it.
2. Work through the tipsheet steps, and check the NPN fields on your profile before you save.
3. Sign every agreement, then print your certificate.
4. Confirm your NPN on the RCL, save the proof, and send it to each carrier that asks.
5. Fold registration into your ACA Open Enrollment preparation.

This guide is general information, not legal or compliance advice. Confirm each requirement with CMS, your carriers or upline, and your compliance team. You'll find more guides in our insurance sales category, and our editorial policy explains how we research them.