GAO Report Highlights Persistent ACA Enrollment Fraud and Regulatory Gaps in 2024

The Government Accountability Office (GAO) released a report in December 2025 highlighting ongoing challenges with unauthorized changes and enrollment fraud in Affordable Care Act (ACA) plans, despite new rules enacted in mid-2024 to prevent such issues. Florida resident cases and insurance agent experiences illustrate the persistence of unauthorized plan switching and enrollment fraud, which can result in consumers facing unexpected premium bills or loss of access to healthcare providers. The Centers for Medicare & Medicaid Services (CMS) reported over 275,000 complaints related to unauthorized ACA enrollments and plan-switching in 2024, underscoring the scale of the problem. The GAO's report follows years of warnings from the agency to federal officials about vulnerabilities in ACA enrollment processes, dating back to earlier administrations. Its investigation included undercover testing where fake enrollments were submitted using counterfeit information, with many applications approved and subsidies paid despite fraud indicators. The findings reveal systemic gaps in identity verification and risk assessment by CMS, including ineffective three-way call requirements meant to confirm consumer consent during plan changes. Lawmakers remain divided on how to address ACA enrollment fraud. Republican proposals in the One Big Beautiful Bill Act advocate for enhanced eligibility verification, while Democratic initiatives seek to impose criminal penalties on brokers who knowingly submit false enrollment information. However, legislative consensus has not been reached, and federal efforts to curb unauthorized broker activity have had limited long-term impact. The report also analyzed enrollment data revealing suspicious patterns, such as multiple ACA applications linked to the same Social Security numbers, including one case with 125 policies under a single number. Approximately 160,000 policies were flagged as potentially compromised by rogue brokers in 2024, a figure substantially lower than some critics’ estimates of millions of fraudulent enrollments. CMS suspended around 850 brokers in October 2024 due to suspected involvement in unauthorized enrollments, though all were later reinstated. CMS implemented three-way call rules in July 2024 requiring agents, consumers, and marketplace representatives to verify certain plan changes; however, loopholes remain, such as reliance on publicly available consumer information and exemptions for new applicants. State-run ACA marketplaces in 20 states plus the District of Columbia report fewer issues with unauthorized switching due to more rigorous authentication measures and use of proprietary websites, contrasting with the federal marketplace's struggles. Industry representatives advocate for stronger identity verification practices like two-factor authentication to better secure ACA enrollments. The GAO report highlights that CMS has not updated its fraud risk assessments since 2018, despite exponential growth in ACA enrollment, contributing to ongoing vulnerabilities exploited by fraudulent actors. The report is preliminary, with final recommendations expected by mid-2026, and congressional hearings scheduled to discuss findings. This investigation underscores the complex regulatory and compliance challenges facing CMS and lawmakers in safeguarding ACA marketplaces from enrollment fraud and unauthorized plan changes, which bear significant consequences for consumers, insurers, and federal subsidy expenditures.