CMS has released its Contract Year 2027 Medicare Advantage and Medicare Part D Proposed Rule, outlining policy updates that could reshape how plans operate, how benefits are structured, and how agents conduct compliant marketing and enrollment activities. While still in the proposal stage, these changes offer an early look at what may impact AEP planning, marketing workflows, and agent operations in future years.
Below is a clear breakdown.
CMS proposes additional regulatory updates tied to the multi-year Part D redesign, including:
• Adjustments to deductible, initial coverage, and catastrophic thresholds.
• Codifying the transition from the Coverage Gap Discount Program to the Manufacturer Discount Program (effective January 2025).
• Updated calculations for out-of-pocket costs and reinsurance.
Why it matters:
These changes continue to shift how Part D plans structure drug benefits. Agents should expect updated formularies, cost-sharing designs, and new competitive differences between plans.
The proposed rule includes:
• Refinements to the Star Ratings measures and weighting.
• Not moving forward with the planned “Health Equity Index” reward.
• Continuing the use of the historical reward factor.
Impact on agents:
Star Ratings influence plan selection and consumer perception. Revisions may shift how plans position quality and how agents compare options during consultations.
CMS highlights rapid enrollment growth in Chronic Condition SNPs (C-SNPs) among dual-eligible individuals and is concerned that these plans may not fully integrate Medicare and Medicaid benefits.
CMS issued a Request for Information seeking input on C-SNP and I-SNP use among dual-eligible populations.
Why this matters:
Future actions may impact SNP structures, marketing practices, and how agents assess suitability for complex or dual-eligible clients.
In addition to policy updates, CMS is proposing several operational and compliance adjustments that could significantly streamline agent workflows.
The proposal removes the mandatory 48-hour delay between collecting a Scope of Appointment (SOA) and holding a sales presentation.
Impact:
Agents would only need an SOA before the presentation begins — restoring a simpler, pre-2023 process.
CMS proposes removing the rule requiring a 12-hour separation between educational and marketing events.
Impact:
Agents and agencies can structure events more efficiently without downtime between formats.
CMS proposes allowing SOAs to be collected during educational events again, as long as the actual marketing discussion does not begin until after the SOA is signed.
Impact:
This reopens a compliant pathway from education to appointment setting.
Call recording retention for enrollment-related calls would be reduced to 6 years, aligning with most other Medicare retention standards.
Impact:
Reduced long-term storage costs and easier record management for call centers and FMOs.
CMS proposes updates that may include:
• Removing the requirement to mention SHIP.
• Removing the requirement to read the disclaimer within the first minute of a call.
Impact:
A more streamlined conversation flow and less beneficiary confusion, while still maintaining transparency.
CMS is considering relaxing rules requiring objective substantiation for subjective terms in marketing materials.
Note:
CMS may still require accuracy and fairness; this is not blanket permission for exaggerated claims.
CMS may update definitions to distinguish between different types of TPMOs, rather than treating all marketing and distribution partners the same.
Impact:
Expect clearer regulatory expectations for:
• FMOs
• call centers
• lead vendors
• technology/marketing platforms
• independent agents
This could reduce confusion and unnecessary blanket requirements.
Monitor carrier updates.
Plans will soon begin evaluating how the proposed changes affect their 2027 offerings and compliance processes.
Review current marketing and event procedures.
If finalized, event spacing rules, SOA practices, call disclaimers, and recording retention could change significantly.
Stay engaged through the comment period.
Public comments are open until January 26, 2026, giving agents, FMOs, and industry groups an opportunity to influence final policy.
The 2027 proposed rule represents a meaningful shift in both Medicare policy and compliance operations. From Part D redesign details to streamlined SOA and event rules, CMS is signaling an effort to balance beneficiary protections with more practical, less burdensome requirements for agents and organizations.
Staying informed now ensures agents can adapt smoothly when CMS finalizes the rule and carriers begin implementing changes.
Medicare keeps evolving, and the right partner helps you evolve with it. At PSM Brokerage, we provide the tools, training, and support agents need to stay compliant, competitive, and confident.