Medicare AEP 2026 Is Here: What Agents Need to Know About 2027 Changes

Medicare AEP 2026 is officially underway.

From October 15 through December 7, people with Medicare can review their coverage and make changes that generally take effect January 1, 2027. Medicare.gov calls this period Open Enrollment; agents and carriers commonly call it AEP.

For agents, this AEP brings more than the usual surge in consumer activity. New CMS marketing rules remove some of the timing restrictions that shaped previous enrollment seasons, while changes to Medicare Advantage and Part D for 2027 are giving beneficiaries new reasons to review their coverage.

Here are the changes, numbers and operational issues Medicare agencies should have on their radar this AEP.

What beneficiaries can change during AEP

During AEP, beneficiaries can generally switch from one Medicare Advantage (MA) plan to another, move from Original Medicare to MA, return from MA to Original Medicare, and join, drop or change Part D prescription drug coverage. One caution for conversations about leaving MA: AEP itself does not create a blanket federal guaranteed-issue right to Medigap.

A client moving back to Original Medicare may face medical underwriting in most states unless a guaranteed-issue right or state protection applies.

Before setting expectations, agents should review Medicare.gov’s guaranteed-issue guidance and applicable state requirements.

The 48-hour SOA waiting period is gone

The CMS Contract Year 2027 final rule removed the 48-hour waiting period between collecting a Scope of Appointment (SOA) and holding a personal marketing appointment. It also removed the 12-hour gap between an educational event and a marketing event in the same location, as long as attendees are told that a marketing event will follow and are given the chance to leave before it begins.

The new marketing and communications policies apply to contract year 2027 marketing beginning October 1, 2026. Do not over-read the change. An SOA is still required before a personal marketing appointment, and it still needs to be properly documented and retained.

Carrier scripts, disclaimers and approved materials may also have changed, so agencies should work from current carrier and compliance guidance rather than relying on last year’s process. The practical effect is speed. A consumer who requests Medicare information in the morning may now be able to schedule and have the appropriate plan conversation that same day.

That makes the gap between consumer interest and agent contact even more important.

What clients will ask about for 2027

CMS published its 2027 projections on September 28.

These are national averages, not quotes for any individual beneficiary.

• MA premiums: the weighted average monthly premium is projected to fall from $14.37 to $12.00.
• Part D inside MA plans: the average Part D premium for Medicare Advantage plans with drug coverage is projected to fall from $11.32 to $7.00 after rebates.
• Stand-alone Part D: the average premium is projected to increase from $35.09 to approximately $36 as the Part D Premium Stabilization Demonstration winds down.
• Access: more than 99% of beneficiaries are projected to have access to at least one Medicare Advantage plan, while 97% are projected to have access to ten or more options.

For 2027, the standard Part D deductible rises from $615 to $700 and the annual out-of-pocket threshold increases from $2,100 to $2,400. Premiums do not count toward that threshold.

National averages also hide important local differences. Idaho’s average Medicare Advantage premium is projected to rise from $27.81 to $37.93, while Connecticut’s is projected to rise from $16.89 to $25.31, even as the national average declines — as CMS’s state-by-state landscape fact sheets show.

Plan availability, provider networks, prescription coverage and benefits still vary by ZIP code and individual circumstances. The national Medicare Advantage plan count is relatively stable overall, but some states are losing plans. Maryland moves from 63 Medicare Advantage plans to 47, while Illinois moves from 157 to 136.

Consumers receiving plan termination notices may have options beyond simply choosing another Medicare Advantage plan, including guaranteed-issue Medigap rights in certain situations. These conversations may take more time and care than a routine plan comparison.

More Medicare Leads Don’t Automatically Mean More Enrollments

Lead counts are easy to see and easy to misread. Imagine Agency A buys 500 leads per day and reaches 10% of them, while Agency B receives 150 leads and reaches 40%. Agency A gets 50 conversations.

Agency B gets 60. The numbers are hypothetical, but the point is simple:

What happens after the lead arrives often determines the outcome.

Agencies should monitor performance by source and, where useful, by state. Important metrics include:

• Speed to first contact
• Contact rate
• Qualified conversation rate
• Appointment rate
• Show rate
• Enrollments submitted
• Enrollments approved
• Cost per enrollment

A source with a low cost per lead but very few real conversations is not necessarily cheap.

Match the lead format to your operation

Different acquisition formats create different operational requirements.

Medicare Web Leads

Web leads give agencies flexibility and allow teams to build larger pipelines. But they depend heavily on immediate CRM delivery and fast, consistent follow-up. An inquiry that sits untouched for hours can lose much of its value.

Medicare Inbound Calls

Inbound calls connect an agent with someone who has already taken the additional step of picking up the phone. They can work particularly well for agencies with strong phone coverage. But every missed call is still a missed opportunity.

Medicare Live Transfers

Live transfers connect a screened consumer with an available agent in real time. They can reduce the amount of time agents spend repeatedly dialing unresponsive records. The model works best when agents are actually available when transfers arrive.

What to ask any Medicare lead vendor

Whichever format you use, ask the vendor:

• How and when was consumer consent captured?
• Can consent records be produced if needed?
• Are leads exclusive or shared?
• How are calls recorded?
• How are leads or calls delivered?
• What does the return or replacement policy cover?
• How are marketing language and required disclosures handled?

If a complaint occurs, your agency and carriers may need to understand exactly where the consumer originated.

Agencies comparing acquisition models can review our Medicare lead options, including web leads, inbound calls and live transfers.

Do not buy more volume than your team can work

AEP creates urgency. That urgency can cause agencies to scale too quickly. If a team can properly work 100 new opportunities per day, sending it 300 does not automatically create three times the sales.

Instead, it may create:

• Slower follow-up
• Unanswered inquiries
• Missed calls
• Poor consumer experiences
• Agent overload
• Wasted acquisition spend

Before increasing volume, know how many agents are actually available. Know how many conversations each agent can realistically handle. Know how quickly web leads are contacted.

Know what happens to missed calls. Know how evening and weekend inquiries are handled. Volume only helps when the operation has the capacity to work it.

Judge AEP in weeks, not days

AEP runs for nearly eight weeks. Some days will bring cancellations, unanswered calls and no-shows. Other days will be excellent.

Evaluate trends instead of reacting to one difficult day. If contact rate falls, investigate why. If one state or traffic source generates a large number of leads but very few conversations, look deeper before scaling.

If calls are producing strong conversations but agents cannot answer enough of them, fix capacity before purchasing additional volume. AEP is also not the last Medicare enrollment opportunity. People already enrolled in a Medicare Advantage plan generally have a separate Medicare Advantage Open Enrollment Period from January 1 through March 31.

Compliance at higher volume

The rules changed this year, but the obligations did not disappear. Scopes of Appointment still need to be documented. Calls still need to be handled, recorded and retained according to applicable CMS, carrier and organizational requirements.

Benefit claims still need to match approved materials.

Agencies should review the CMS Contract Year 2027 final rule alongside current carrier and compliance guidance.

Moving fast is valuable. Moving fast without documentation creates risk. Two other 2027 changes may affect daily operations.

CMS moved the third-party marketing organization (TPMO) disclaimer from the first minute of a call to before plan benefits are discussed. CMS also reduced the minimum retention period for certain marketing and sales call recordings from ten years to six years: the audio recording must be kept for the first three years, and either the audio or a transcript for years four through six.

Enrollment-related records may still have different or longer requirements, and carriers or FMOs may impose stricter standards. Agencies should confirm applicable requirements before changing retention practices.

CMS training materials: CY 2027 Medicare Advantage and Part D Marketing Regulation Training.

Where Freedom Marketing Group fits

Freedom Marketing Group LLC provides Medicare web leads, consumer-initiated inbound calls and live transfers for insurance organizations. But leads are only half of the equation. The agencies that get the most value from any acquisition source usually have the staffing, follow-up process and performance tracking required to properly work the opportunities they receive.

A strong AEP strategy therefore combines traffic, people, process, speed and measurement.

If you are planning to add volume this AEP:

Sources

• CMS — Medicare Advantage and Medicare Prescription Drug Programs Expected to Remain Stable in 2027
• CMS — 2027 Medicare Advantage and Part D Landscape State-by-State Fact Sheets
• CMS — Contract Year 2027 Medicare Advantage and Part D Final Rule
• Federal Register — Contract Year 2027 Final Rule
• CMS — CY 2027 Medicare Advantage and Part D Marketing Regulation Training
• CMS — CY 2027 Medicare Advantage Capitation Rates and Part C and Part D Payment Policies
• Medicare.gov — Open Enrollment
• Medicare.gov — Medigap Guaranteed-Issue Rights

Freedom Marketing Group, LLC is not affiliated with or endorsed by Medicare, CMS or any government agency. This article is general information, not legal or compliance advice; always follow current CMS and carrier requirements. No lead or call type guarantees enrollment or sales.