3 Operational Moves To Make Before Open Enrollment Begins

• October 26, 2026

By Scott Morrison

With the countdown to open enrollment winding down, health insurance brokers must ensure their technology systems are ready for launch day on Nov. 1. 

In September, the Centers for Medicare & Medicaid Services (CMS) announced a temporary moratorium on new federal exchange registrations for the 2027 plan year. CMS also strengthened consumer authorization and identity-proofing requirements through enhanced direct enrollment (EDE) platforms that allow private-sector websites on which consumers can shop for, enroll in and manage marketplace health plans without going directly to HealthCare.gov.

Enforcement now happens up front. With EDE, missing a credential or failing a tech requirement triggers an automatic application programming interface (API) lockout that immediately prevents a broker from submitting applications. Preparation can’t wait until launch day, or even the day before.

Here are three steps to avoid spending open enrollment manually entering applications or navigating carrier websites one by one.

1) Confirm access. EDE platform connectivity is not guaranteed. CMS requires EDE vendors to meet technical, security and compliance standards. Confirm that your enrollment platform is approved and operational for open enrollment.

Run test scenarios through your system. Check that consent forms log automatically, consumer authorization workflows function as expected, API calls complete without error codes, and carrier confirmation numbers return smoothly.

Because of the moratorium on new broker registrations, each broker must verify their exchange status well before launch day, and agencies should confirm that all team members’ credentials are active and their multifactor authentication (MFA) methods work.

The new EDE requirements also necessitate additional training. Staff must know how to obtain and document consumer consent before accessing consumer information or taking action on their behalf, and how to complete the separate consumer authorization process through their EDE platform. Train staff on consumer identity-proofing requirements, including procedures for applications that require additional verification.

2) Have a backup ready. You need a backup plan in case your platform goes out of commission during open enrollment. With the high volume of activity, even a short period of downtime is costly.

Consider credentialing your agency on a compliant, secondary EDE platform. Vet the vendor for exchange access, but also look at carrier connectivity, standardized integrations, automated compliance safeguards, unified workflows, reliable transaction execution and bulk data ingestion capabilities.

Also, establish a clear agency switchover protocol before opening day. Define the exact operational threshold—such as prolonged API downtime or system latency—that triggers transitioning to a secondary platform.

3) Know how to transfer your book. If an outage or regulatory suspension forces your agency to switch systems, you cannot afford to leave your client history behind or manually rekey data row by row. Clean up and reconcile your data and then audit both export and import mechanics before opening day.

Check where and how client records are downloaded and run a test export. Ensure essential data fields are present and complete. Finding out on Nov. 2 that an export takes 48 hours to process through vendor support is an operational disaster.

Additionally, run a test import, as well by uploading a small, anonymized sample batch of client records into your secondary system to verify that fields map cleanly and records populate without errors.

Open enrollment is a 10-week sprint. When client volume spikes, every lost hour costs revenue, and every stalled application risks client trust. With stricter oversight in place, you cannot afford to assume your tools will work when you flip the switch on Nov. 1. Take the time to prepare now.

Scott Morrison is general manager at W3LL, a technology company focused on modernizing broker and agency tools and resources for better business growth and management.