As states and the federal government continue to develop their eligibility and enrollment systems for health benefit exchanges, it is important to keep in mind that an online application is not simply a form, but an information system that will collect, maintain and make decisions based on sensitive personal and financial data. Consequently, it is critical that this system include a process for accurately credentialing online users, to ensure that a user is who she says she is. This credentialing process involves two fundamental steps: 1) identity proofing of individuals who seek to become eligible for health coverage; and 2) ongoing authentication of individuals once eligibility has been determined.