When can you start marketing, and how does your first AEP work?
No marketing before October 1. Selling opens October 15 and closes December 7. Coverage starts January 1. As a new plan you send no ANOC — but every competitor does, by September 30, and the benefit cuts disclosed in those ANOCs are the largest single driver of AEP switching.
That is your opening.
What this stage actually is
Six weeks that determine your year-one membership, preceded by four weeks in which nothing may be said publicly and everything must be ready.
What you must do
- Submit marketing materials per CMS material-submission rules and obtain HPMS material IDs. Nothing may be used before October 1.
- Train and certify agents and brokers, and file agent and broker compensation in HPMS. For plan year 2027, CMS set a hard deadline of July 31, 2026 for MA organisations to submit and attest to compensation data — expect an equivalent CY2028 deadline in July 2027.
- Validate Medicare Plan Finder data. Your Plan Finder listing is the highest-traffic surface you have, and you do not control it directly.
- Stand up enrollment intake, call centre capacity and member fulfilment — ID cards, welcome kits, EOC.
- Execute the AEP plan across broker, direct and community channels.
What changed for marketing, effective October 1, 2026
The CY2027 Final Rule (published April 6, 2026) rolled back several 2023-era marketing restrictions. These are the rules you will operate under:
- The 48-hour waiting period between Scope of Appointment and a personal marketing appointment is eliminated. SOA may be collected at the start of an appointment, on the same call, or at the same event.
- Agents may collect SOAs at educational events, and the 12-hour gap between an educational and a marketing event at the same venue is removed, with attendee notification.
- Superlatives (“best”, “most”) are permitted where the claim is substantiated.
- The TPMO disclaimer must be delivered before any discussion of plan benefits, replacing the “first 60 seconds” standard.
- Call recordings need only be retained six years.
- National maximum commissions rise: MA initial $694 → $725, MA renewal $347 → $363, Part D initial $114 → $130 (renewal $65).
What this means for a new entrant: broker-led acquisition just got easier and more expensive at the same time. Do not carry a 2025-era distribution cost model into your CY2028 bid.
Key dates
| What | When | Date status |
|---|---|---|
| Agent/broker compensation attestation in HPMS | Jul 31, 2026 → ~Jul 2027 | published → projected |
| ANOC received by members (competitors) | Sep 30 | statutory |
| Marketing may begin | Oct 1 | statutory |
| AEP | Oct 15 – Dec 7 | statutory |
| Coverage effective | Jan 1 | statutory |
| MA Open Enrollment Period | Jan 1 – Mar 31 | statutory |
About the dates on this page. CY2027 dates are published CMS facts. CY2028 dates marked statutory are fixed by regulation. Dates marked projected are the pattern from the CY2026 and CY2027 cycles — CMS has not published them yet, and we relabel them the day it does. How we label data and dates →
CMS forms, systems and references
- Medicare Communications and Marketing Guidelines
- CY2027 Final Rule — marketing provisions effective October 1, 2026
- ANOC and EOC model documents
- MA and Part D enrollment and disenrollment guidance
Common mistakes
- Treating AEP as the only window. For a new plan, MA OEP (Jan 1 – Mar 31) and year-round dual and LIS special enrollment periods frequently deliver more year-one members than AEP.
- Material submission bottlenecks in September. Build the review calendar backward from October 1.
- Under-staffing weeks 1–3. A new plan has no volume baseline and consistently under-staffs the opening surge. The CAHPS damage lands in the year your first star rating is measured.
Tips for success
- Target disruption, not the general population. A member whose plan is exiting, reducing its service area or cutting benefits is several times more contestable than a satisfied one — and the ANOC on September 30 tells you which ones they are.
- Build one battlecard per major incumbent per county, with dated facts.
- Instrument everything from day one. Your first AEP is the only baseline you will ever get.
The data you need for this stage
- AEP target markets — contestable-member ranking
- Sales intelligence — carrier battlecards and the disruption calendar
- Policy impact — the marketing-rule tracker
So what / Now what
Your first AEP is six weeks long and follows four weeks in which you are legally silent. Everything that determines its outcome — materials, certification, Plan Finder accuracy, staffing — has to be finished before it starts.
- Re-model distribution economics under the CY2027 commission and SOA changes before you finalise the bid.
- Build the material submission calendar backward from October 1.
- Rank your contestable markets in AEP target markets.
Provenance — sources and date status
- Source files
- Medicare Managed Care Manual, Chapter 11; CY2027 MA and Part D Final Rule; CY2027 Rate Announcement; CY2027 Part D Bidding Instructions
- Vintage
- CY2027 cycle published; CY2028 cycle not yet posted by CMS
- Last updated
- July 24, 2026
- Refresh cadence
- At each CMS cycle milestone (application posting, Advance Notice, Rate Announcement, final rule)
- Method
- CY2027 dates are transcribed from CMS materials. CY2028 dates are either statutory (bid = first Monday in June; Rate Announcement = first Monday in April; ANOC receipt = Sep 30; marketing start = Oct 1; AEP = Oct 15–Dec 7) or projected from the CY2026 and CY2027 cycle pattern.
- Known limitations
- Projected dates are not CMS commitments and must be confirmed against the CMS application page and HPMS memos when the CY2028 cycle opens. Network adequacy standards and application procedures change between cycles — verify current-cycle instructions rather than reusing prior-year guidance.
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