How to prepare for new AEP rules

The Centers for Medicare and Medicaid Services has changed some of the rules around how we work, while carriers are changing benefits, networks, eligibility requirements and supplemental programs. Here’s what agents need to know to be prepared for Annual Election Period.

New CMS marketing rule for AEP?

CMS finalized the Contract Year 2027 Medicare Advantage and Part D rule on April 2. Several changes affect how you conduct business during AEP.

These changes include:

• The 48-hour Scope of Appointment waiting period is gone. Licensed insurance agents can discuss a plan immediately after an SOA.
• Superlatives are no longer categorically prohibited. Terms such as "best" or "top" are no longer subject to the prior blanket prohibition, but any claims must be accurate and supportable.
• Record retention is changing. CMS is reducing the required period from 10 years to six years, with specific requirements for how calls must be maintained.
• Educational and marketing event rules have been loosened. The physical separation requirements have been reduced.
• Third-party marketing organization disclaimer requirements are changing. You must provide the disclaimer before discussing specific plan benefits, instead of relying on the former 60-second framework.

Don’t continue to operate under last year’s rules; understand the new rules and sell what best fits your client’s needs.

The bigger story: Benefits are changing

The defining story of this AEP isn't simply premiums. It’s benefit design and selling compliantly.

Carriers are looking closely at utilization, costs and the sustainability of supplemental benefits. That means you need to look beyond the Summary of Benefits and ask a much more important question:   What does this benefit mean for this client?

Transportation, over-the-counter, food, dental, vision and other supplemental benefits can change year to year. And even when a benefit remains, its eligibility requirements, dollar amount or participating vendors may change.

That's where you must slow down, rely on technology and be the trusted advisor your client deserves.

C-SNPs and SSBCI will require a different level of preparation

Chronic Condition Special Needs Plans (C-SNPs) are designed for people with qualifying chronic conditions, and CMS maintains specific criteria governing which chronic conditions can qualify. But here's the important part: Having a chronic condition doesn't automatically mean a client qualifies for every benefit associated with a C-SNP or SSBCI program.

Special Supplemental Benefits for the Chronically Ill (SSBCI) are benefits that plans can offer qualifying chronically ill members when the benefit meets CMS requirements. CMS continues tightening the guardrails. For 2027, that means clarifying SSBCI eligibility requirements, requiring plans to post their own SSBCI criteria publicly, and adding new requirements around debit-card administration and real-time verification of eligible products and services.

One carrier's qualifying criterion may not match another carrier's. One plan may require documentation, a particular diagnosis, a health-risk assessment, a provider confirmation or another qualification process before a benefit can be accessed. You can’t simply tell a client, "You have diabetes, so you get the grocery benefit."

The right conversation is: “Let's determine whether you qualify for this specific benefit under this specific plan and understand what the carrier requires to activate or access it."

That distinction matters.

Don't overlook the changes affecting dual-eligible clients

If you work with dual-eligible beneficiaries, pay close attention to D-SNP changes going into 2027.

CMS is implementing additional requirements affecting certain D-SNPs, including restrictions around enrollment in certain plans when the beneficiary is not enrolled in an affiliated Medicaid managed care organization. In other words, Medicaid status, state requirements and the specific carrier's D-SNP structure matter. You can't rely on a generic understanding of "dual eligibility."  You must know the plan.

This is where the trusted advisor really matters.

The best technology doesn't replace the licensed insurance agent; it gives you more time to identify plan changes, compare benefits and prepare for the conversation.

But as a licensed insurance agent, you still must ask:

1. Has your client's health changed?
2. Are their doctors and medications still covered?
3. What benefits did they use last year?
4. Which supplemental benefits are important to them, and do they still qualify for them?
5. What does the carrier require to access those benefits?
6. Has anything changed with their Medicaid or chronic-condition eligibility?

That conversation creates value.

MA vs. Medigap: Match the product to the person

With more than half of Medicare beneficiaries enrolled in Medicare Advantage, MA remains central to the market. But the right answer isn't always the plan with the lowest premium.

When working with Medicare Advantage clients, look at networks, prescription drugs, prior authorization, maximum out-of-pocket exposure and the supplemental benefits they value.

When working with Medigap clients, look at premium, provider access, underwriting considerations and the client's expected healthcare needs.

Ask every client these three simple questions:

1. How much unpredictability can your budget absorb?
2. How important is access to specific doctors and hospitals?
3. What healthcare needs do you anticipate over the next few years?

That's how you move the conversation from "Which plan is cheapest?" to "Which plan fits me?"

Run the cost conversation differently this AEP

Don't sell this AEP on a one-year premium snapshot. Look at the bigger picture.

Compare premiums, Part D costs, maximum out-of-pocket exposure, provider access, drug coverage and the benefits the client uses. And remember: the richest benefit isn’t valuable if the client can’t access it.

That's why carrier-specific training will be so important this year. You need to know not only what a carrier offers, but who qualifies, what documentation may be required, how the benefit is activated, where it can be used and what limitations apply. That will separate prepared, licensed insurance agents like you from those simply quoting plans.

The opportunity this AEP

AEP 2027 will reward preparation. Update your compliance workflows. Review the 2027 plan changes. Understand C-SNP eligibility. Know the SSBCI requirements. Pay attention to D-SNP and Medicaid requirements. And most importantly, understand the carriers and plans you represent.

Clients don’t need another salesperson reading from a benefit summary; they need a licensed insurance agent who understands what these changes mean for them.

Let's make this our most prepared — and most successful — AEP yet!

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Angela Palo is the chief operating officer and co-owner of Pinnacle Financial Services, an AmeriLife company. Contact her at [email protected].