CMS Improves Plan Transparency and Choice with 2027 MA and Part D Final Rule

The Centers for Medicare & Medicaid Services (CMS) released their Medicare Advantage (MA) & Part D Final Rule for Contract Year 2027 on April 2, 2026.

These updates are great news for agents selling Medicare plans as the final rule seeks to reduce friction, preserve consumer choice, and emphasizes clarity and transparency.

Read the press release from CMS or access the full Final Rule for more details.

Here is a breakdown of the changes that are most important for agents to know!

What Changes Were Finalized

Overall, CMS is making updates to improve the Medicare shopping experience while strengthening consumer protections.

No More 48-Hour Waiting Period

Agents may now contact clients immediately after obtaining a signed Scope of Appointment (SOA). This means that agents can have valuable conversations on the same day and on the same call. This update allows agents to help beneficiaries when they ask for it.

Best practices for agents:

• Explain in plain language what products will be discussed
• Confirm understanding before moving into plan-specific details
• Treat the SOA as consumer education — not just paperwork

Simplified Call Recording Rules

Now, only calls that result in an enrollment must be recorded. Client calls made to ensure plan satisfaction or respond to general benefit questions do not require recording.

Please note, marketing calls must still be retained for six years. Audio needs to be stored for three years and transcripts for an additional three years. Enrollment records still must be retained for 10 years.

We encourage agents to use a centralized system to record calls and maintain client documentation to simplify compliance and reduce your administrative burden.

Flexible Educational and Marketing Events

Educational and sales events can be great opportunities to connect with beneficiaries in spaces that make sense for them. CMS has updated policy surrounding these events to assist clients and agents!

Agents may now host educational and sales/marketing events on the same day. The previous 12-hour buffer period has been eliminated.

Agents must clearly communicate to attendees that the meeting is transitioning and grant them a genuine opportunity to leave the event before sales-specific discussions begin.

To stay compliant when hosting educational and marketing events on the same day:

• Clearly announce when education ends and sales begin
• Use signage or slides stating “Sales/Marketing Event”
• Give consumers a real opportunity to leave without pressure
• Complete the SOA before discussing specific plans

Clarified TPMO Disclaimer Requirements

Agents are still required to mention the TPMO disclaimer, but only before plan benefits are discussed in a call. This disclaimer no longer needs to be mentioned in the first minute of a call.

This change reduces confusion by allowing agents to first explain the purpose of the call and establish clear expectations before presenting required disclosures.

Important reminders for agents:

• CMS marketing flexibility does not override TCPA
• Obtain proper consent for calls and texts
• Honor opt-outs immediately
• Ensure lead sources are TCPA compliant — not just CMS compliant

Special Enrollment Period Updates

Some Special Enrollment Periods (SEP) require CMS validation. When applicable, enrollments under these SEPs must take place through Medicare.gov or by calling 1-800-MEDICARE.

Agents still play a key advisory role in these situations. You are responsible for guiding beneficiaries, explaining what options are available, and helping them to outline next steps, even if you’re not completing the enrollment yourself.

Overall, these changes are good news for agents and clients! As you navigate client conversations moving forward, remember to slow down if clients aren’t understanding or need more time. Be transparent instead of focusing on a possible sale.

Your clients are the lifeline of your business, and it’s up to you to document clearly and ensure their satisfaction. Agents who succeed under the 2027 Final Rule are agents who pair efficiency and professionalism.

For a handy compliance checklist and more advice, download Integrity’s CMS CY 2027 Final Rule handout!

To serve clients better this year and beyond, register with Ritter today for access to proprietary technology and the support of a full Sales team.