CMS is taking a more aggressive approach to Marketplace program integrity. On September 22, 2026, the agency announced that it had canceled approximately 315,000 unauthorized enrollments covering more than 760,000 individuals. According to CMS, the effort is part of a broader push to address fraudulent and improper enrollment activity and is expected to return roughly $2.2 billion in advance premium tax credit payments.

The announcement reflects a three-part strategy: preventing improper enrollments before they occur, removing enrollments that CMS determines were unauthorized, and increasing oversight of agents and brokers participating in the Exchanges.

A key feature of CMS’s approach is continued coordination with health insurance issuers. CMS stated that it will work with issuers to identify potentially unauthorized enrollments, investigate those cases, cancel enrollments confirmed to be unauthorized, and recoup associated APTC payments. For issuers, these actions may also raise operational issues, including the potential need to refund premiums for impacted enrollees back to the federal government, to recoup capitation payments to providers, to recoup commissions paid to agents and brokers for the unauthorized enrollment, and to adjust financial forecasts and actuarial models.

CMS also is focusing on agent and broker conduct. Since January 2026, the agency has issued termination notices to more than 200 non-compliant agents and brokers. This summer, CMS issued 569 notices of intent to terminate to agents and brokers who submitted 2026 applications without key applicant information, such as Social Security numbers. CMS also published an interim final rule, Temporary Moratoria on Certain Agent and Broker Registration to Participate in the Exchanges, which temporarily pauses registration for agents and brokers that do not have a current Plan Year registration with the Federally-facilitated Exchanges. CMS described the moratorium as a bridge while it implements additional program-integrity safeguards aimed at preventing unauthorized enrollment activity, misuse of consumer personally identifiable information, and other conduct that threatens consumers and Exchange integrity.

The takeaway: CMS is signaling a heightened enforcement posture for Marketplace enrollments and Exchange-related agent and broker activity. Issuers should expect continued scrutiny of potentially unauthorized enrollments, while agents and brokers should expect closer review of application practices and compliance with Marketplace standards.