The AEP 2027 Playbook for Medicare Agents: Before, During and After Annual Enrollment
AEP runs October 15 through December 7, and the agents who win it do three things. They finish certifications, plan reviews and capacity planning before October 15. They run a documented, compliant process (SOA, TPMO disclaimer, recorded calls) on every appointment during it. And they protect the book with service and retention touches after December 7 and into the January 1 to March 31 MA Open Enrollment Period.
AEP is not a sprint you show up for on October 15. It is a deployment. The work that decides your season gets done in August and September. If you are reading this on October 12, you have three days. That is enough to close the gaps that sink agents in November, if you spend it on the right things.
This is the plan I would hand any agent, first AEP or fifteenth. It runs in order: before, during and after. Every compliance rule below is tied to a current CMS source for contract year 2027, because several rules changed this year. No hype. Just the work.
AEP 2027 at a glance: the dates that matter
AEP: October 15 to December 7, 2026 (coverage starts January 1, 2027)
The Annual Enrollment Period runs October 15 through December 7, 2026. Changes made during AEP take effect January 1, 2027, and the plan must receive the enrollment request by December 7. An application that sits in your queue on December 7 is not an enrollment. Medicare.gov lists the Open Enrollment dates and effective dates.
MA OEP: January 1 to March 31, 2027
The Medicare Advantage Open Enrollment Period runs January 1 through March 31, and it is only for people already enrolled in a Medicare Advantage plan. During it, an MA member gets one election: switch to another MA plan, or return to Original Medicare and join a separate drug plan. The change takes effect the first of the month after the plan gets the request. Medicare.gov's enrollment period chart lays this out, and the one-change limit is written in 42 CFR 422.62(a)(3).
It does not let someone in Original Medicare move into Medicare Advantage, and nobody gets a second change in February.
Marketing dates vs sales dates
Plans and their agents can start marketing 2027 offerings on October 1, 2026, under 42 CFR 422.2263(a). Enrollment applications for January 1 coverage cannot be taken before October 15 unless the client qualifies for a Special Enrollment Period, per the Medicare Communications and Marketing Guidelines (MCMG). October 1 through 14 is for scheduling, collecting Scopes of Appointment and reviewing ANOCs. Not signatures.
Where SEPs fit
Special Enrollment Periods are tied to specific situations, including a plan that is not renewing. I walked through that conversation in what to do when MA members need a new plan in 2027. Use an SEP only when the client actually qualifies, and document the reason in the file.
Before AEP: the 3-day and 30-day checklist
Get ready to sell with every carrier you will write
No RTS, no app. Every carrier you plan to write needs to show you ready to sell for 2027. That usually means AHIP or the carrier's equivalent, plus product training. CMS requires agents to be trained and tested every year and score 85 percent or higher (42 CFR 422.2274(b)(2)). Pull an RTS report from each carrier portal today. For the links and steps in one place, use the Brock Partners Certification Hub.
Know what changed for 2027
Read the Annual Notice of Change for every plan in your book. 2027 is a disruption year: plan exits, service area cuts, and formulary and network changes. I covered the market side in 2027 carrier exits, where carriers are pulling back and the 2027 carrier scorecard. The ANOCs give your clients' details.
Segment your book before the phones start
Split your book into three groups. First, clients affected by an exit or a major change in doctors, drugs or cost get the first calls. Second, stable clients whose plan barely moved get a lighter touch. Third, clients on a Special Needs Plan or getting Extra Help need their own approach, because different enrollment rules apply. The SNP growth trends for 2027 are worth reading before you work that group.
Check your tech and compliance stack
Dry test everything you touch on an appointment: quoting tool, CRM, SOA workflow, secure document storage and call recording. Recording has to capture every marketing and sales call, including the audio of video calls. Place a test call on each line and video platform, then find the recording and play it back. If you cannot retrieve it, you do not have it.
Set your capacity before the phone rings
Most agents plan their marketing and never plan their calendar. Capacity is a decision you make before October 15, not something you discover in week three. Napkin math: say you work ten hours and hold back three for service and admin. That leaves seven. If a real appointment, with prep and documentation, takes about 90 minutes, your ceiling is four or five a day, not eight.
Those numbers are an example. Use your own. Set the ceiling, block the calendar and protect service time, because agents who book past capacity cut corners, and corners are where compliance problems live. If you hit that wall every year, read how to scale your agency without burning out.
Lock your lead plan
Know where your appointments come from for the next eight weeks. If you are still deciding, read my thoughts on T65 lead sources and on why buying leads burns new agents.
During AEP: run the same process on every appointment
The compliant appointment flow, step by step
Your strongest protection is boring consistency: same steps, same order, every appointment.
Scope of Appointment first. CMS requires an SOA before any personal marketing appointment (42 CFR 422.2274(b)(3) and 422.2264(c)(3)). For in-person appointments it must be in writing, and electronic counts. For contract year 2027, the 48-hour waiting period is gone under final rule CMS-4212-F, so you can hold the appointment any time after the SOA is completed, including the same day. See the CMS summary of CY 2027 marketing changes. An SOA is generally valid for 12 months, and any product outside the original scope needs a new one. Follow stricter carrier rules where they apply.
TPMO disclaimer before benefits. If you sell for more than one MA organization, you must say the disclaimer verbally before you discuss any benefits. The old "within the first minute" timing no longer applies. If you do not offer every plan in the area, the required wording is: "We do not offer every plan available in your area. Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options." If you represent every organization, use the shorter version in the table below.
Needs analysis. Health, budget, travel and priorities before you open a quote.
Doctors, drugs and pharmacies. Verify every provider and every prescription. Not most of them. All of them.
Plan comparison. Compare on total cost and fit, not premium alone.
Enrollment. Complete the application accurately, with the client.
Recap. What they chose, why, the effective date, and what happens next.
Recorded calls: what CMS requires
This rule changed for 2027, so read it straight from 42 CFR 422.2274(g)(2)(ii): "All marketing and sales calls, including the audio portion of calls conducted via web-based technology, must be recorded and retained in their entirety for a minimum period of 6 years. For the first 3 years of the retention period, records must be maintained in audio format. For years 4, 5, and 6, records may be maintained in either audio format or as complete and accurate transcript recordings." CMS cut the retention period from 10 years to 6 in the CY 2027 final rule. Your carrier and upline may set their own storage rules, so check those too.
Needs-based, not plan-pushing
Every enrollment needs a written reason a stranger could understand. Note the doctors, the drugs, the total cost comparison, travel needs, and any dental, vision or hearing need the client raised. That note protects the client and your contracts. If you cannot write down why a plan fits, do not enroll it.
Plan-change conversations when a plan exits or cuts benefits
These calls make or break trust this year. Lead with facts: what is changing, when, and what it means for their doctors, drugs and costs. Then walk through the options and let them choose. Never call anything "free," never guarantee a benefit or a price, and never call a plan "the best plan." The full framework is in the MA members post linked above.
Med Supp clients during AEP
AEP does not change Medigap underwriting. A client moving to a different supplement during AEP faces the same underwriting rules as any other month. Never let a client drop a supplement before the new policy is approved. Approval first, then cancellation.
Daily cadence: work the plan
Run your day in blocks: appointments in core hours, service in a protected block, admin at the end. Before you shut down, review every file: SOA on file, disclaimer given, recording saved, reason documented, application submitted. That self-audit catches mistakes while the call is fresh.
Protect yourself and your team from burnout
I learned discipline in the Marine Corps, and the lesson carries over. Discipline outlasts motivation, and rest is part of the mission. A schedule with sleep, meals and a real day off is what gets you to December 7 still making good decisions. If you lead a team, enforce it for them too. Tired agents make compliance mistakes.
After AEP: retention is where the book is built
A pile of applications is not a book of business. The book gets built after December 7, when most agents go quiet and clients find out how their new plan works.
December 8 to December 31: confirm everything
Check every application for rejections, pending status and missing information, and fix them before January 1. Then make a welcome call to each new client. Confirm the plan, the effective date, and who to call when something goes wrong. That should be you.
January: the drug-fill check
January is when problems surface. ID cards arrive late, primary care assignments are wrong, and pharmacies do not have the new plan on file. Call new clients in early January and ask three questions. Did your card arrive? Is your primary care doctor right? Did your prescriptions go through at the pharmacy? Few agents make that call, and it solves problems before they become complaints.
MA OEP: service beats shopping
Clients churn during the MA OEP for predictable reasons: a pharmacy surprise, an out-of-network doctor, or nobody answering their call. Good service in January prevents most of it. Help your own clients who come to you with a problem. Do not cold call people to switch them, and remember that unsolicited calls to former enrollees who have disenrolled or are disenrolling are prohibited under 42 CFR 422.2264. I go deeper on this in how Medicare agents build a real book of business.
Annual review rhythm and referral asks
Put every client on the calendar for an annual review before next AEP. When a client is happy, ask whether they know someone who could use the same help. Follow current CMS and carrier rules for contacting anyone they mention, and never pay cash for referrals.
Measure your season
Run your own after-action review. Track your appointment-to-application ratio, rejections, chargebacks, rapid disenrollments, and how many clients are still with you after the MA OEP. Compare against your own last season, not someone's highlight reel. If the numbers show a skills gap, fix it before spring with Medicare agent training for building a real book.
AEP compliance quick reference
Rule | What it means | Source |
|---|---|---|
Scope of Appointment | Document an SOA before any personal marketing appointment. In writing for in-person (electronic is fine). No 48-hour wait for CY2027. Valid 12 months; new SOA for products outside the scope. | 42 CFR 422.2274(b)(3); 42 CFR 422.2264(c)(3); CMS-4212-F |
TPMO disclaimer | Say it verbally before discussing benefits; show it on websites, materials and electronic messages. If you represent every organization: "Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. You can always contact Medicare.gov or 1-800-MEDICARE for help with plan choices." | |
Call recording | Record every marketing and sales call in full. Keep 6 years: audio for years 1 to 3, audio or transcripts for years 4 to 6. | 42 CFR 422.2274(g)(2)(ii) |
Educational vs marketing events | No plan marketing at educational events, but SOAs can be collected. A marketing event may follow in the same location if attendees are told and can leave. | 42 CFR 422.2264(c); CMS CY2027 marketing changes |
Unsolicited contact | No unsolicited door-to-door contact; limits on unsolicited calls. Follow carrier and upline rules too. | 42 CFR 422.2264(a); MCMG |
Sharing beneficiary data | Share beneficiary data with another TPMO only with prior express written consent naming each recipient. | 42 CFR 422.2274(g)(4) |
Gifts and rebates | No cash or monetary rebates. Gifts only within nominal gift limits under current CMS marketing rules, regardless of enrollment. |
How Brock helps agents through AEP
We built Brock around this same sequence. On training, we run Agent Bootcamp and Behind the Agency, and our agent resources cover the guides and checklists agents ask for most in season. On tools, GoGuruX and the Brock Portal handle the CRM, marketing and back-office side; see our tools page. Medicare Monsters by Brock is where our agents trade real questions during AEP, and our support desk handles the contracting and RTS issues that pop up in October.
Our Brock events include Brockapalooza, our invite-only gathering for Brock partners in September 2027.
FAQs
When is AEP 2027?
AEP runs October 15 through December 7, 2026, and changes take effect January 1, 2027. The plan must receive the enrollment request by December 7. The Medicare Advantage Open Enrollment Period follows from January 1 through March 31, 2027, and it is only for people already enrolled in a Medicare Advantage plan. Source: Medicare.gov.
Do I still have to wait 48 hours after a Scope of Appointment?
No. For contract year 2027, CMS final rule CMS-4212-F eliminated the 48-hour waiting period. You still must secure and document an SOA before any personal marketing appointment, but the appointment can happen any time after the SOA is completed, including the same day. In-person SOAs must be in writing, and electronic counts.
Do I have to record AEP sales calls?
Yes. Under 42 CFR 422.2274(g)(2)(ii), all marketing and sales calls, including the audio of web-based calls, must be recorded in full and kept for at least 6 years. The first 3 years must be audio. Years 4 through 6 can be audio or complete, accurate transcripts. Check carrier and upline storage policies too.
What is the TPMO disclaimer and when do I say it?
It is the CMS standardized statement that tells beneficiaries how many organizations and products you represent and points them to Medicare.gov or 1-800-MEDICARE. Under 42 CFR 422.2267(e)(41), you must say it verbally on sales calls before you discuss any benefits. It also goes on your website, marketing materials and electronic messages.
Can I enroll clients before October 15?
You can start marketing 2027 plans on October 1, 2026, under 42 CFR 422.2263(a). You cannot take enrollment applications for January 1 coverage before October 15 unless the client qualifies for a Special Enrollment Period. Use the first two weeks of October to schedule appointments, collect SOAs and review ANOCs with clients.
What should agents do after AEP ends?
Confirm every enrollment and fix rejections or pending apps before January 1. Make welcome calls in December. In January, check that ID cards arrived, primary care assignments are right and first prescriptions filled. Then stay in touch through the MA Open Enrollment Period so clients get service from you instead of shopping somewhere else.
The Bottom Line
AEP is won before October 15, run on process through December 7, and kept from December 8 through March 31. Get ready to sell this week. Set your capacity. Run the same compliant flow on every appointment. Then do the January work most agents skip.
Prep the mission. Run the process. Protect the client. Keep the book.
Want a second set of eyes on your AEP process? Book a call with the Brock team. And if your RTS is not done yet, start with the Certification Hub linked above before October 15.
