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The Affordable Care Act marketplace is facing a major eligibility review that could affect more than a million people, although the groups involved are not all in the same situation. The Centers for Medicare & Medicaid Services said it canceled about 315,000 Marketplace enrollments on Aug. 31, affecting more than 760,000 individuals after confirming that the enrollments were unauthorized. Federal officials are also reviewing roughly 419,000 additional enrollees for immigration status and income eligibility, meaning being flagged for review does not by itself establish that someone committed fraud.
More Than 760,000 People Already Lost Their Coverage
CMS said the Aug. 31 action canceled approximately 315,000 Marketplace enrollments covering more than 760,000 people after the agency and insurers investigated and confirmed that the enrollments were unauthorized. The agency expects approximately $2.2 billion in advance premium tax credits associated with those canceled enrollments to be returned. Officials said the cases involved concerns such as people being enrolled without authorization or problems verifying information needed for Marketplace eligibility.
Another 419,000 Enrollees Face Additional Checks
The administration says another group of roughly 419,000 people will undergo additional checks involving legal residency and income requirements. Reuters reported that officials said these individuals are being reviewed to confirm that they meet the requirements for ACA Marketplace coverage and subsidies. This group is different from the more than 760,000 people whose enrollments CMS says were already confirmed as unauthorized, so the review should not be interpreted as proof that every person in the additional group is improperly enrolled.
Why Agents and Brokers Are Under Scrutiny
Much of the federal enforcement effort is focused on insurance agents and brokers who help consumers enroll in Marketplace plans. CMS said it has sent termination notices to more than 200 non-compliant agents and brokers since January 2026, while 569 additional agents and brokers received notices of intent to terminate Exchange Agreements after submitting 2026 applications without required identifying information such as Social Security numbers. CMS also announced a temporary moratorium on registering agents and brokers for the 2027 plan year if they do not have an active 2026 Exchange Agreement.
New Safeguards Are Being Added to Marketplace Enrollment
CMS says it is adding several safeguards designed to prevent unauthorized applications and make it harder for agents or brokers to act without a consumer’s knowledge. Agents and brokers are now required to complete identity proofing through Login.gov or ID.me, while applications involving agents or brokers must include verifiable Social Security numbers or immigration document numbers for non-newborn applicants. CMS also says it plans to require electronic consumer authorization before an agent or broker can take action on an application or enrollment.
The ACA Marketplace Is Already Smaller in 2026
The latest enrollment data show that the ACA Marketplace was already experiencing a significant decline before this new enforcement action. KFF found that effectuated Marketplace enrollment fell from 21.8 million people in 2025 to 19.2 million in February 2026, a 12% decrease that coincided with the expiration of enhanced premium tax credits at the end of 2025. KFF also reported that average monthly premium payments rose 58%, from $113 in 2025 to $178 in 2026, although consumers’ costs vary depending on income, plan choice and eligibility for financial assistance.
Higher-Income Enrollees Have Seen Major Changes
The expiration of the enhanced tax credits has particularly affected people who previously received larger subsidies because of the temporary rules. KFF found that consumers with incomes above 400% of the federal poverty level accounted for 48% of the decline in Marketplace plan selections from 2025 to 2026, even though they represented only 7% of 2025 enrollment. The same analysis found that people with incomes above 400% and up to 500% of the poverty level saw plan sign-ups fall by 44%, illustrating how changes in subsidy eligibility can affect coverage decisions.
The Fraud Concerns Come With Important Questions
There is evidence that the Marketplace has been vulnerable to improper enrollment, but the size and nature of the problem remain important parts of the debate. The Government Accountability Office previously reported that investigators using fictitious identities were able to obtain subsidized ACA coverage, while federal officials say their current review has identified unauthorized enrollments and suspicious broker activity. At the same time, people who lose coverage or are subjected to verification are not necessarily personally responsible for an unauthorized enrollment, particularly when an agent or broker may have acted without their knowledge.
What Enrollees Should Check Right Now
Anyone with ACA Marketplace coverage should check their account, read recent notices and make sure their income, household and identification information is accurate. People who lose qualifying health coverage may generally qualify for a Special Enrollment Period if they act within 60 days, while those who lose Medicaid or CHIP coverage may have up to 90 days, according to HealthCare.gov. Consumers should also keep documentation showing a loss of coverage or other qualifying circumstances because the Marketplace may require proof before new coverage takes effect.
What the Latest ACA Review Could Mean for Enrollees
The federal review represents a significant change in how the Marketplace is checking enrollment information, with hundreds of thousands of existing enrollments already canceled and hundreds of thousands more subject to additional verification. CMS says the effort is intended to remove unauthorized enrollments, recover improper subsidy payments and strengthen protections against broker-related abuse, while outside observers have raised questions about how the reviews will affect people whose coverage information is difficult to verify. The situation is unfolding as the ACA Marketplace enters another period of higher consumer costs and changing enrollment patterns, making it important for enrollees to monitor official notices and verify their coverage status.