AEP 2027 Readiness: A Five-Week Countdown for

The short answer

The Annual Enrollment Period for the 2027 plan year runs 15 October to 7 December 2026. Coverage starts 1 January 2027. Updated CMS marketing guidelines take effect 1 October 2026 — two weeks before AEP opens — and the 2027 Medicare Advantage and Part D final rule loosened several rules agents have worked around for years.

If you are reading this in early September, you have roughly five weeks. Here is what to do in each of them.

What actually changed for 2027

The 2027 MA and Part D final rule took effect on 1 June 2026, with updated marketing guidance applying from 1 October 2026. Several changes remove friction that agents have complained about for years.

Change	Old rule	2027 rule
Scope of Appointment timing	48 hours between SOA and appointment	Eliminated
Educational → marketing event gap	12-hour waiting period	Removed
SOA collection at educational events	Not permitted	Permitted
TPMO disclaimer timing	Within the first 60 seconds	Before discussing plan benefits
Superlatives in marketing	Prohibited	Permitted with substantiation
Call recording retention	Ten years	Six years

Two of these change how you run your week. The elimination of the 48-hour SOA rule means a lead who calls you ready to enroll can be enrolled in that conversation rather than two days later — which makes speed-to-lead worth considerably more than it was last season. And being able to collect SOAs at educational events turns every seminar into a pipeline event rather than a brand exercise.

The one to be careful with is superlatives. "Permitted with proper substantiation" is not "permitted." If you claim you are the top agency in your county, you need the evidence on file before the claim goes out, not after a complaint arrives.

On the benefit side, the Part D out-of-pocket cap rises to $2,400 for 2027, up from $2,100 in 2026. That is a talking point in every drug-cost conversation you will have this season.

Why the market pressure is real this year

Medicare Advantage enrollment reached 35.2 million people in 2026 — 55% of the 64.2 million Medicare beneficiaries with Parts A and B, up about 1.1 million (3%) year over year, according to KFF. The Congressional Budget Office projects MA reaching 63% of beneficiaries by 2034.

At the same time, choice narrowed. The average beneficiary had 32 MA-PD plans available in 2026, down from 34 in 2025, and the national plan count fell 9% to 3,373 plans (KFF). Fewer plans and continued exits mean more involuntary shopping — beneficiaries whose plan left the market and who must make a decision. Those are the highest-intent conversations of the season, and they land in October.

The 2027 landscape data lands in late September. Do not build your talk track before you have it.

The five-week countdown

Week of 7 September — clean the data

Nothing you do in October works if the list is dirty. This week is unglamorous and non-negotiable.

Export your full book and last season's non-converts.

De-duplicate. Merge records with the same phone number, keep the richest one.

Re-scrub the entire list against DNC. Numbers move onto the registry constantly, and a scrub from last November is not a scrub. In APEX, DNC scrubbing runs on import, so re-importing a cleaned CSV re-scrubs it — up to 50,000 rows at a time.

Fix time zones. Your quiet-hour enforcement is only as good as the state and area-code data behind it.

Tag by cohort: current clients, aged leads, T-65 approaching, and plan-exit prospects once you know who they are.

Week of 14 September — rebuild the sequences

Write the follow-up now, while you have time to write it well. In October you will not.

Build three separate sequences, not one:

Existing clients. An annual review invitation. This is your highest-yield, lowest-effort revenue, and most agents underwork it.

Aged leads. Re-engagement referencing the new enrollment window.

Plan-exit prospects. Held until the landscape data confirms which plans left which counties.

Every sequence needs delays measured in days, a clear opt-out, and — critically — stop-on-reply, so nobody receives touch four the day after they enrolled with you. Build them once and they run all season.

Week of 21 September — certifications and compliance

Complete carrier certifications and AHIP if you have not.

Confirm your TPMO disclaimer language, and confirm your team knows the timing changed: it is now required before discussing plan benefits, not within the first sixty seconds.

Confirm your call recording is running and that your retention practice matches the six-year requirement.

Review your consent records. Prior express written consent is still required for marketing calls and texts to wireless numbers under 47 CFR 64.1200(f)(9). The FCC's one-to-one consent rule was vacated in January 2025, but nothing about the underlying consent obligation changed, and statutory damages remain $500 per violation — $1,500 if willful or knowing.

Week of 28 September — the calendar and the landscape

Publish your availability. Block the hours you will actually be free and let leads book into them. An appointment booked by the lead shows up more reliably than one you scheduled at them.

Turn on SMS appointment reminders. No-shows in AEP are the most expensive kind, because the slot cannot be refilled.

Read the 2027 landscape files as soon as they publish. Identify plan exits and significant benefit changes in your counties.

Update your talk track with real 2027 numbers, including the $2,400 Part D cap.

Week of 5 October — dry run

Dial a test queue of 40 leads. Confirm auto-advance, recording, logging, and dispositions all work as expected.

Send one small SMS batch and watch delivery. Do not discover a messaging problem on 15 October.

Confirm quiet hours block a deliberately out-of-window send. Look at the audit log and confirm the block is recorded.

Decide your daily structure: which hours are dial blocks, which are appointments, which are admin. Write it down.

Marketing guidelines take effect on 1 October — before AEP opens. Anything you send from that date forward is subject to them.

During AEP: the operating rhythm

Fifty-four days. The agents who finish strong are the ones who do the same thing every day rather than the ones who sprint the first week.

Two dial blocks a day, protected. Morning and late afternoon, adjusted for the lead's time zone rather than yours.

Same-day follow-up on every no-answer. Automated, so it happens whether or not you remember.

Appointments in the middle of the day, when people answer the door and the phone.

One admin block, late. Applications, notes, and list hygiene.

A Friday review. Which cohort is converting, which sequence is producing replies, which counties are moving.

The single biggest AEP failure mode is not working too few leads. It is losing track of the ones you already talked to. If a conversation does not end with a scheduled next touch, the lead is gone.

The week after 7 December

Do not stop on the 8th. The Medicare Advantage Open Enrollment Period runs 1 January to 31 March 2027, and beneficiaries who chose badly in AEP get one switch. Everyone you spoke to in November who went another way is a January conversation — but only if the record is clean and the next touch is scheduled.

FAQ

When is AEP for the 2027 plan year?

15 October to 7 December 2026, with coverage effective 1 January 2027. Updated CMS marketing guidelines apply from 1 October 2026.

Did the 48-hour Scope of Appointment rule really go away?

Yes. The 2027 MA and Part D final rule eliminated the 48-hour waiting period between collecting an SOA and holding the marketing appointment, and it permits SOAs to be collected at educational events. The SOA itself is still required — only the timing restriction was removed.

When does the TPMO disclaimer have to be read now?

Before discussing plan benefits, rather than within the first 60 seconds of the interaction. In practice this is a small change with a real operational consequence: it has to be built into your script at the right point rather than tacked onto the opening.

Can I use superlatives like "best" in my 2027 marketing?

Only with proper substantiation on file. The rule permits them; it does not permit unsupported claims. If you cannot produce the evidence for the claim, do not make it.

How long do I have to keep Medicare call recordings?

The 2027 final rule reduced the retention requirement to six years. Confirm your own state requirements as well, since some are stricter.

What should I do first if I am starting late?

Data hygiene, every time. A clean, de-duplicated, freshly DNC-scrubbed list with correct time zones is worth more in the first week of AEP than any sequence you could write. Clean the list, then build one re-engagement sequence for existing clients. Those two things alone will carry you.

AEP 2027 Readiness: A Five-Week Countdown for Medicare Agents