Integration Guide
Compliance considerations
If you build on HealthSherpa ONE and display quoting results or support enrollment workflows, you may be subject to CMS web-broker requirements. You are responsible for how your application presents plans, markets coverage, and interacts with consumers.
These considerations summarize selected CMS expectations that commonly apply to quoting and enrollment integrations. They do not replace legal review, CMS registration requirements, or your obligations under the HealthSherpa ONE API Terms of Service.
Plan steering & non-discriminatory display
Per 45 CFR § 155.220(c)(3)(i)(L)–(M), applications built on the quoting API may not display QHP advertisements or recommendations, or give any plan favored or preferred placement, based on the compensation your organization receives from a carrier. If your application ranks, sorts, or highlights specific plans by default, you must prominently disclose the methodology behind that ranking to the consumer.
See CMS’s Direct Enrollment Partners resource hub for CMS materials on default plan display and comparison tools, including web-broker guidance for the Federally-facilitated Marketplaces.
Marketing conduct standards
Per 45 CFR § 155.220(j)(3)(iii)(A), applications may not offer cash, monetary rebates, gift cards, travel vouchers, or cash equivalents as an inducement for enrollment. Non-cash gifts to consumers are permitted only when they meet the nominal-gift standards in 45 CFR § 155.220(j)(3)(iii)(B): of nominal value, offered to similarly situated consumers regardless of whether they ultimately enroll, and not a cash equivalent.
Zero-dollar premium claims (New for Plan Year ’27)
Per 45 CFR § 155.220(j)(3)(iii)(C), your application may not falsely assert or suggest that a consumer will always qualify for zero-dollar insurance or zero-dollar premiums. Premium and subsidy amounts vary by individual eligibility. Unqualified claims, including references to “$0” premiums or “free” ACA coverage without noting that eligibility and cost vary by consumer, are prohibited for Plan Year ’27 marketing on the Federally-facilitated Marketplace and State-based Exchanges on the Federal platform. See CMS’s 2027 Notice of Benefit and Payment Parameters final rule fact sheet for additional context.