AEP 2027 Compliance Training Slide 1 of 12
AEP 2027 Compliance Training
Annual Enrollment Period — Plan Year 2027
Estimated time: ~10 minutes
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For licensed agents only  |  The Health Experts Insurance  |  Confidential
Module 1
What is AEP?
Understanding the Annual Enrollment Period
Key Dates

October 15 – December 7, 2026

Coverage begins January 1, 2027

What Beneficiaries Can Do During AEP
  • Switch from one Medicare Advantage (MA) plan to another
  • Switch from Original Medicare to a Medicare Advantage plan
  • Drop MA and return to Original Medicare (with or without Part D)
  • Join, switch, or drop a Medicare Part D prescription drug plan
Important Rule
Beneficiaries can only make ONE election during AEP. The last enrollment submitted is the one that takes effect — "last one wins."
Module 2
Who Can Enroll?
Eligibility requirements for AEP enrollment
Basic Eligibility Requirements
  • Must be enrolled in both Medicare Part A and Part B
  • Must live within the plan's geographic service area
  • Must not be currently enrolled in end-stage renal disease (ESRD) — with certain exceptions under ESRD rules effective 2021
SEPs — Outside AEP

Special Enrollment Periods (SEPs) allow qualified beneficiaries to make changes outside the standard AEP window. Always verify SEP eligibility before enrolling outside Oct 15 – Dec 7.

Verify Before You Enroll

Always confirm the beneficiary's Medicare Part A & B status and service area before completing an enrollment. Submitting ineligible enrollments can result in compliance violations.

Module 3 — NEW for 2027
SOA Requirements
Scope of Appointment — Critical compliance update
Major Change for PY2027

48-Hour Waiting Period ELIMINATED

Same-day appointments are now permitted after the SOA is obtained — effective October 1, 2026

What Changed
  • Same-day appointments now permitted after SOA is obtained
  • Electronic signatures accepted
  • Effective October 1, 2026 for PY2027 enrollments
What Stayed the Same
  • SOA is STILL required before every personal marketing appointment
  • SOA valid 12 months if product scope unchanged
  • New SOA required when adding products outside original scope
Source: CMS Final Rule 42 CFR §§ 422.2264(c)(3) and 423.2264(c)(3)
Module 4
CMS Marketing Rules
Required standards for all marketing activities
  • Only use CMS-approved and carrier-approved materials
  • No door-to-door solicitation unless the beneficiary initiates the contact
  • No cold calling unless the prospect has given prior expressed permission
  • No marketing in healthcare settings (exam rooms, pharmacy counter, etc.)
  • No providing meals as inducements to enroll
  • Events must be educational in nature — not sales appointments
  • All marketing materials must include required CMS disclaimers
Approved Materials
Access all approved materials through your carrier portals and YourFMO. Never modify or alter approved materials. Using unapproved materials is a CMS violation.
Module 5
What You CAN Do
Permitted activities during AEP 2027
Permitted Activities
  • Conduct appointments after SOA is obtained — same-day is now OK for PY2027
  • Discuss only the products listed on the signed SOA
  • Use approved marketing materials from carrier portals
  • Hold educational events following CMS event rules
  • Follow up with leads who have provided expressed interest / permission
  • Use Sunfire or carrier portals to complete enrollments
Reminder — Certifications Must Be Current
AHIP certification and all required carrier certifications must be completed and approved BEFORE you begin any marketing or sales activities for PY2027.
Module 6
What You CANNOT Do
Prohibited activities — violations carry serious consequences
Prohibited Activities
  • Market or sell products outside the documented SOA scope
  • Promise or guarantee benefits not confirmed by the carrier
  • Use misleading, altered, or unapproved marketing materials
  • Contact prospects by phone without prior expressed interest/permission
  • Conduct marketing in prohibited settings (healthcare facilities, pharmacies)
  • Offer gifts, meals, or other inducements to influence enrollment decisions
Consequences of Violations
CMS violations can result in agent contract termination, civil monetary penalties, and CMS sanctions. Protect your license — always follow the rules.
Module 7
Enrollment Process
Step-by-step guide to compliant AEP enrollments
  1. 1
    Obtain SOA Before the Appointment Get a signed Scope of Appointment from the beneficiary before any marketing meeting. Electronic signatures accepted.
  2. 2
    Conduct the Compliant Marketing Appointment Same-day meetings now permitted for PY2027. Follow all CMS marketing guidelines.
  3. 3
    Present Only Approved Plan Materials Use only carrier-approved materials. Discuss only products listed on the SOA.
  4. 4
    Complete Enrollment via Sunfire or Carrier Portal Submit the enrollment accurately through Sunfire or the appropriate carrier portal.
  5. 5
    Confirm Enrollment Confirmation Sent to Beneficiary Verify the beneficiary receives their enrollment confirmation from the carrier.
  6. 6
    Retain All Documentation Keep SOAs, appointment notes, and materials used per CMS retention requirements.
Coverage Effective Date
Enrollments submitted by December 7, 2026 take effect January 1, 2027.
Module 8
Key Deadlines
Critical dates for AEP 2027 — mark your calendar
October 1, 2026
New SOA Rules Take Effect — 48-hour waiting period eliminated. Same-day appointments now permitted after SOA is obtained.
October 15, 2026
AEP Opens — Annual Enrollment Period begins. Agents may begin submitting PY2027 enrollments.
December 7, 2026
AEP Closes — Last day to enroll for January 1, 2027 coverage. No late exceptions.
January 1, 2027
Coverage Effective Date — PY2027 plans begin for all AEP enrollees.
Before You Market — Certifications Required

AHIP certification and all required carrier certifications must be completed and approved BEFORE conducting any marketing or sales activities for Plan Year 2027. Do not begin marketing without confirmed certification status.

Module 9
Compliance Reminders
Final guidance before your knowledge check
Golden Rule

When in doubt, don't. Check the YourFMO compliance portal before taking any action you're uncertain about. It's always better to pause and verify.

Document Everything

Retain SOAs, appointment notes, and records of all materials used. CMS retention requirements apply. No documentation = no proof of compliance.

Compliance Resources
  • CMS Helpline: 1-800-MEDICARE
  • THEI Compliance Support: compliance@healthexps.com
  • YourFMO Compliance Portal — available in your agent dashboard
Violations Have Consequences
Non-compliance can result in agent contract termination, civil monetary penalties, and CMS sanctions. Your license is your livelihood — protect it by following every rule, every time.
Knowledge Check
AEP 2027 Quiz
Answer all 6 questions. You need 5 or more correct to pass.
Question 1 of 6
When does AEP 2027 open for enrollments?
A
September 15, 2026
B
October 15, 2026
C
November 1, 2026
D
October 1, 2026
AEP opens on October 15, 2026. Note: October 1 is when the new SOA rules take effect — different from when AEP opens.
Question 2 of 6
The 48-hour SOA waiting period for PY2027:
A
Is still required for all appointments
B
Has been extended to 72 hours
C
Has been eliminated starting October 1, 2026
D
Only applies to phone appointments
Correct! CMS Final Rule eliminated the 48-hour waiting period effective October 1, 2026. Same-day appointments are now permitted once the SOA is obtained.
Question 3 of 6
Do you still need an SOA before conducting a personal marketing appointment?
A
No — the SOA requirement was eliminated along with the waiting period
B
Only if the client is new to Medicare
C
Yes — SOA is still required before every personal marketing appointment
D
Only for MA plans, not PDP
The SOA requirement is still in effect. Only the 48-hour waiting period was eliminated — not the SOA itself. You must obtain an SOA before every personal marketing appointment.
Question 4 of 6
How long is an SOA valid?
A
30 days
B
6 months
C
Until the end of AEP
D
12 months, as long as the product scope does not change
An SOA is valid for 12 months, provided the product scope documented in the SOA remains unchanged. A new SOA is required if you need to discuss products not listed on the original SOA.
Question 5 of 6
Which of the following is NOT allowed during AEP?
A
Conducting a same-day appointment after the SOA is obtained
B
Using carrier-approved marketing materials
C
Offering a free meal to a prospect to encourage enrollment
D
Following up with a lead who expressed interest
Providing meals or gifts as inducements to influence enrollment decisions is explicitly prohibited by CMS. This is a common compliance mistake. Options A, B, and D are all permitted activities.
Question 6 of 6
When does AEP 2027 coverage take effect for beneficiaries who enroll during AEP?
A
December 7, 2026
B
January 1, 2027
C
October 15, 2026
D
February 1, 2027
Coverage for all AEP 2027 enrollments takes effect January 1, 2027 — regardless of when during Oct 15 – Dec 7 the enrollment was submitted.
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AEP 2027 Compliance Training
Annual Enrollment Period — Plan Year 2027
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