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OE27 Identity Verification & Risk Management: Essential Reference Guide for Agents 1. Overview of the OE27 CMS Policy Updates The Centers for Medicare & Medicaid Services (CMS) has established significant compliance mandates taking effect for Open Enrollment 2027 (OE27). Under these updated rules, CMS requires Enterprise-Differentiated Enrollment (EDE) partners to enforce risk-based consumer identity proofing and explicit consumer authorization across all agent- and broker-as