Frequently Asked Questions: National Producer Number (NPN) Override
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Rules and FAQs governing when agents, brokers, web-brokers, and business entities may use an NPN that is not an individual's own on Federally-facilitated Marketplace or State-based Marketplace (Federal Platform) applications; applies to Marketplace-registered agents, brokers, web-brokers and business entities assisting consumers.
No material clinical or coverage changes in this revision.
NPN Use and Registration Criteria
NPN use and registration criteria
Conditions under which a business entity or affiliated agents may use the same NPN on Marketplace applications and the registration requirements:
ALL of the following
- Each agent or broker using the business entity NPN has completed Marketplace registration and the required annual training for the applicable plan year.
- Each agent or broker using the business entity NPN has signed the applicable Marketplace Agreements with CMS for the applicable plan year.
- Each agent or broker using the business entity NPN has appropriate issuer appointments and complies with applicable state laws and regulations and CMS regulations, including 45 C.F.R. 155.220(j).
Permitted and Prohibited NPN Submission Actions
When you may and may not submit another person's NPN on a Marketplace application
Agents, brokers, and web-brokers may, in some cases, submit a Marketplace application using an NPN that is not their own, but only if they comply with Marketplace requirements (including 45 C.F.R. 155.220(j)), applicable Marketplace agreements, and state laws and regulations. Do not submit another person's NPN when any of the prohibitions below apply.
- Do not submit a different NPN in states that require appointments when the individual actively assisting the consumer is not appointed with the issuer of the plan in which the consumer enrolls.
- Do not use referral programs as a means to circumvent state appointment rules; the agent who receives the referral must be the one actively assisting the consumer and must be appointed with the issuer.
- Do not submit another's NPN if you do not have documentation of consumer (or Authorized Representative) consent and confirmation that the application information is accurate.
- Do not submit another's NPN if you are not licensed in your resident state and the state of enrollment (when different).
- Do not submit another's NPN if you have not completed Marketplace registration, required training, and signed the applicable Marketplace Agreements with CMS for the applicable plan year.
Key Definitions
OpenPayer is powered by Trek Health's payer performance platform. Trek continuously ingests, validates, and normalizes Transparency in Coverage data alongside payer policies and other commercial payer data to create a structured payer intelligence foundation. OpenPayer uses this foundation to deliver personalized search results, dynamically generated policy pages, and tailored policy monitoring based on each user's payers, specialties, billing codes, and areas of interest. The same intelligence powers broader payer performance workflows, including reimbursement benchmarking, contract evaluation, payer negotiations, and financial decision-making.