This article explains what an NPN override is, when NPN overrides are and are not permitted, which states and carriers prohibit NPN overrides, and how MyMFG handles NPN override restrictions during the enrollment process.
What Is an NPN Override?
An NPN override — also referred to as an Agent of Record (AOR) override, NPN swapping, or using a principal NPN — is a feature in insurance enrollment platforms that allows an agent to submit a Marketplace application using a National Producer Number (NPN) other than their own. NPN overrides are used in situations such as commission sharing arrangements or when submitting an application under an appointed agent's credentials.
When NPN Overrides Are Permitted
CMS permits agents, brokers, and web-brokers to submit a Marketplace application using an NPN that is not their own in certain circumstances, provided all applicable CMS requirements, Marketplace agreements, and state laws and regulations are followed.
A business entity may have its affiliated agents and brokers submit the same NPN — such as the NPN of an agency owner or principal — on Marketplace applications, as long as all agents and brokers using that NPN have:
Completed Marketplace registration and required training for the applicable plan year
Signed the applicable Marketplace Agreements with CMS for the applicable plan year
Obtained appropriate issuer appointments
Complied with applicable state laws and regulations and CMS regulations, including 45 C.F.R. 155.220(j)
When NPN Overrides Are Not Permitted
CMS has identified situations in which an agent, broker, or web-broker may not submit an NPN that is not their own when assisting with or facilitating a Marketplace consumer enrollment or eligibility application. The following is a non-exhaustive list of prohibited scenarios:
The agent actively assisting the consumer is not appointed with the issuer of the plan in which the consumer enrolls, in a state that requires appointments. Referral programs cannot be used as a means to circumvent state appointment rules. The agent who receives the referral must be the one actively assisting the client and must be appointed with the issuer.
The agent actively assisting the consumer does not have documentation of consumer consent and review and confirmation of the accuracy of eligibility application information.
The agent actively assisting the consumer is not licensed in their resident state and the state of the enrollment, if different.
The agent actively assisting the consumer has not completed Marketplace registration and required training, or has not signed the applicable Marketplace Agreements with CMS for the applicable plan year.
NPN overrides may never be used as a means to violate Marketplace requirements or state laws and regulations, including licensure and appointment requirements.
States Where NPN Override Enrollments Are Prohibited
NPN overrides are prohibited for enrollments in the following states. Agents enrolling clients in these states must submit the application under their own NPN:
Florida
Iowa
Michigan
New Hampshire
North Carolina
South Dakota
Wisconsin
Carriers That Do Not Permit NPN Overrides in Any State
The following carriers do not permit NPN overrides regardless of the state of enrollment:
UnitedHealthcare (UHC)
Ambetter
How MyMFG Handles NPN Override Restrictions
MyMFG automatically identifies when an NPN override is being attempted for a prohibited state or a carrier that does not permit NPN overrides. In these situations, MyMFG displays a yellow warning on the final enrollment submission page to inform the agent of the restriction.
The yellow warning is not a hard block. However, if the agent proceeds and signs and submits the application, MyMFG will submit the application under the agent's own NPN, not the overridden NPN. The NPN override will not be applied in any scenario where the state or carrier prohibits it.
Agents should review the warning carefully before submitting. Submitting an enrollment in a prohibited state or with a prohibited carrier without correcting the NPN will result in the application being recorded under the agent's individual NPN.
What agents will see when an NPN override is not available during a MyMFG enrollment
What agents will see when an NPN override is not available during a MyMFG enrollment
Resources
For requirements in a specific state, contact its Department of Insurance. For more information about situations where NPN override should not be used, refer to the guidance issued by the Centers for Medicare & Medicaid Services (CMS).
Additional Resources
For help using MyMFG or for other assistance, contact Producer Support. Producer Support is available by phone at , by email at [email protected], or by chat directly from your account.
For agency specific needs, contact our Agency Support team at [email protected]