Enhanced Direct Enrollment (EDE)

What percentage of Marketplace enrollments are facilitated by an EDE?

We don’t have current data for how many people enrolled via the EDE pathway in recent years; the most recent data published by CMS is from early 2021.⁵

But during the open enrollment period for 2023 coverage, 57% of all active enrollments in the federally facilitated Marketplace were through EDEs and “classic” direct enrollment (DE) entities.⁶ And if we only consider broker-assisted active plan selections, EDE and DE pathways accounted for 81% of them during the open enrollment period for 2023 coverage.⁷

With classic direct enrollment, the DE entity’s website facilitates the enrollment process, but the consumer does have to be directed to HealthCare.gov to complete the eligibility application. They are then redirected back to the DE entity’s website to select a plan and enroll.¹ For the first five years that Marketplaces were operational, classic DE was the only option for entities that wished to partner directly with HealthCare.gov. That changed in the fall of 2018, when the EDE pathway became available.⁸

What entities can provide enhanced direct enrollment?

When the EDE program debuted in 2018,⁸ there were only eight approved EDE entities, including two web brokers and six issuers (insurance companies).⁹ But the program has grown considerably since then. As of August 2024, 73 entities were approved as EDEs. Eleven of them had created their own EDE platforms, while the rest were leasing one of those 11 approved EDE platforms.¹⁰

Most of the EDE entities are issuers, although most of the entities that are hosting their own EDE platforms are web brokers.¹⁰

If an EDE entity is an issuer, it is permitted to display only its own qualified health plans.¹¹ But if the EDE entity is a web broker, it must display all available QHPs that the enrollee would see if they visited HealthCare.gov. If the web broker isn’t able to provide enrollment support for certain QHPs, it “must prominently display a disclaimer provided by the Department of Health & Human Services (HHS) and provide a link to HealthCare.gov”¹¹ that the consumer can use if they wish to enroll in one of the plans for which the EDE does not provide enrollment support.

An EDE entity might not operate in all states that use HealthCare.gov. In that case, the EDE can only assist consumers in states where the EDE operates.²

Two EDEs were suspended by CMS in 2024, due to “anomalous activity” related to unauthorized enrollments and plan changes, and those EDEs are implicated in a civil lawsuit filed by consumers and agents who were affected by the fraudulent enrollments.¹²¹³ The suspended EDEs subsequently filed a lawsuit against CMS in an effort to get their EDE status restored.¹⁴

What rules do EDEs have to follow?

EDEs are prohibited from utilizing marketing approaches that might “mislead a consumer into believing they are visiting HealthCare.gov.” However, they can use certain terminology on their website to clarify their EDE status. This includes the phrases “CMS Partner,” “CMS Approved Enhanced Direct Enrollment Entity,” “Enrollment Partner,” “HealthCare.gov Partner,” “CMS Partner Website,” or “CMS Partner Entity.”¹⁵

EDE entities that also offer non-Marketplace plans must display them on a separate page of their website, and cannot market these plans during a consumer’s Marketplace plan selection and enrollment process.⁶

CMS has noted that the process of getting approved as an EDE entity “may take up to a year or more” to complete.²