The Medicare Annual Enrollment Period (AEP) runs Oct 15 through Dec 7. For Medicare-focused agencies, it’s 54 days that produce 60–80% of annual revenue. It’s also the 54 days where one wrong message can suspend your appointment with every Medicare carrier. Here’s how to design the campaign without becoming a cautionary tale.
The three CMS rules that matter most
-
Scope of Appointment (SOA) before any sales conversation. No quoting, no plan comparison, no carrier-specific recommendation without an SOA on file. The SOA must be obtained at least 48 hours before the appointment for first-time prospects.
-
No cold outbound for Medicare Advantage / PDP. You cannot SMS, call, email, or door-knock a Medicare-eligible prospect about MA / PDP without a prior request from the prospect. Permission-marketing only.
-
Carrier-allowance disclosure on every marketing communication. Every email and SMS that mentions a Medicare Advantage or PDP plan must include the carrier-allowance disclaimer.
Violating any of these can result in carrier termination, CMS sanctions, and in some states, license actions.
Audience segmentation for AEP
Inside the snapshot, AEP audiences split into three sequences:
1. Existing policyholders
- Already have a Medicare plan placed by your agency
- SOA on file (you’re already in scope)
- Goal: plan-review conversation, retain or upgrade
Cadence (Oct 1 – Dec 7):
- Oct 1 — “Your annual plan review is coming up — let’s book your call”
- Oct 15 — AEP officially open, calendar reminder
- Nov 1 — “Review window closes Dec 7 — pick a time” (if not yet booked)
- Nov 15 — last-call reminder
- Post-review — confirmation of any plan change or “all set for another year” message
2. Prior-year leads
- Reached out previously but didn’t enroll
- SOA may have expired (renew before any plan discussion)
- Goal: re-engage with permission gate
Cadence (Oct 1 – Dec 7):
- Oct 1 — “AEP is coming — would you like a fresh plan review this year?” (renews SOA if yes)
- If SOA renewed → existing-policyholder cadence
- If no response by Nov 1 — single follow-up, then drop
3. New prospects (educational-led)
- No prior relationship
- No SOA yet (cannot solicit MA / PDP)
- Goal: educate via permission-marketing, capture SOA, enroll
Cadence:
- Permission-marketing educational sequence (Medicare 101, Original vs Advantage, plan-comparison guide)
- “Want to talk to an agent?” CTA in every email → fires SOA form
- Once SOA on file → existing-policyholder cadence
What you can put in marketing copy
Allowed:
- “Medicare AEP runs Oct 15 – Dec 7”
- “Let’s review your plan this year”
- “Want help comparing your options?”
- “Schedule a free consultation”
- General educational content about Medicare programs
Not allowed without SOA + permission:
- “AETNA has a new MA plan with $0 premium” (carrier-specific, requires SOA)
- “Switch to Plan X and save $40/month” (plan-specific solicitation)
- Comparative carrier statements (“Plan X is better than Plan Y”)
- Inducements with non-nominal value ($15+ gifts)
T65 funnel (parallel to AEP)
T65 — turning 65 — is the other big Medicare moment. Unlike AEP, T65 runs year-round. The snapshot tracks every prospect’s birthday and fires:
- T-7 months — educational email
- T-5 months — second educational + SOA invitation
- T-3 months — third touch with “want to talk to an agent?” CTA
- T-1 month (SOA on file) — agent walks through plan options
- At enrollment — confirmation + welcome materials
- Annually thereafter — feeds into existing-policyholder AEP cadence
T65 is the highest-LTV acquisition moment in Medicare. Every new T65 enrollment generates 10–15 years of renewal commissions (Medigap) or annual AEP touchpoints (MA).
The SOA form
The SOA form captures:
- Beneficiary name + DOB
- Plan types being discussed (Original Medicare, Medigap, MA, PDP)
- Date + time of appointment
- Beneficiary signature (electronic, with IP + timestamp)
- Producer name + NPN + writing-state
- 48-hour rule acknowledgment (for first-time appointments)
Records retain for 10 years (CMS requirement). The snapshot stores SOAs in the contact record and exports as a CSV for CMS audit on demand.
OEP (Open Enrollment Period)
Jan 1 – Mar 31 is the OEP — MA enrollees can switch plans or return to Original Medicare. The snapshot fires a OEP-specific cadence for any MA enrollee who expressed concern during AEP, plus a “thank you for renewing” sequence for those who stayed put.
What if you mess up?
If a producer accidentally sends a non-compliant message:
- Document immediately (what was sent, to whom, when, by whom)
- Notify the carrier(s) per their compliance reporting protocol
- If the message reached a Medicare beneficiary, send a follow-up clarifying the message was not a solicitation
- Train the producer; review what process gap allowed it
- Update workflow guardrails so the same mistake can’t repeat
CMS treats good-faith corrections with reasonable leniency. Repeated patterns are what end appointments.
The final-disclaimer
This article is operational guidance, not legal advice. Your agency, your producers, your CMS-appointment status carry the final responsibility for AEP-campaign compliance. Hire a Medicare-specific compliance attorney to review your campaign blueprint before your first AEP under any new system.
The Medicare workflows in the Insurance Snapshot for GHL bake the CMS rules above into hard gates — but you bring the judgment for edge cases. Both pieces matter.