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The 2027 Medicare Advantage Non-Renewal Playbook

How Independent Agents Should Work Non-Renewals, Medigap Guaranteed-Issue Rights, and the Post-AEP SEP

Medicare Advantage plan non-renewals require a different workflow from routine Annual Notice of Change reviews.

For the 2027 plan year, independent Medicare agents should identify affected clients as soon as official carrier notices become available, verify each client’s coverage end date, explain the available Medicare paths without steering, track applicable Medigap Guaranteed-Issue rights, and continue following affected clients through the non-renewal Special Enrollment Period.

The goal is not to create urgency for the sake of a sale.

The goal is to make sure an affected beneficiary understands what is ending, what happens next, and which deadlines apply.

What Is a Medicare Advantage Non-Renewal?

A Medicare Advantage non-renewal occurs when a plan or contract will no longer be offered for the following plan year.

This is different from an Annual Notice of Change, or ANOC.

An ANOC explains changes to a plan that will continue into the next year.

A non-renewal notice tells the beneficiary that the current plan will not continue.

For a plan ending December 31, 2026, the beneficiary will need to make a coverage decision for 2027.

If the beneficiary does not enroll in another Medicare Advantage plan before the current plan ends, Medicare generally returns the beneficiary to Original Medicare when the Medicare Advantage coverage terminates.

That does not automatically provide separate prescription drug or Medigap coverage.

Agents should therefore read the official notice carefully before explaining the beneficiary’s options.

Why Should Agents Separate ANOC and Non-Renewal Workflows?

The documents trigger different conversations.

An ANOC review focuses on changes inside a continuing plan.

A non-renewal conversation focuses on what happens when a plan ends.

For non-renewal clients, agents may need to address:

The date the current plan ends
Replacement Medicare Advantage options
Returning to Original Medicare
Prescription drug coverage
Potential Medigap Guaranteed-Issue rights
Applicable Special Enrollment Periods
Provider and prescription continuity

Do not assume that every client receiving an ANOC is losing coverage.

Likewise, do not describe a plan as terminating unless the carrier’s official notice confirms it.

How Should I Identify Affected Clients?

Start with official carrier information.

Use your CRM to separate:

Watchlist

Clients whose carrier, county, or plan may be affected but whose specific non-renewal has not yet been confirmed.

Confirmed Non-Renewal

Clients for whom you have official plan or carrier confirmation that coverage is ending.

Do not combine those categories.

A useful workflow includes:

Carrier
Plan
County
Current coverage end date
Official notice received
Provider review needed
Prescription review needed
Medigap GI review needed
AEP appointment requested
Non-renewal SEP follow-up
Final coverage selected

OmniReach can be configured to help agents organize these categories and follow-up steps.

The CRM helps organize the workflow. It does not determine whether a beneficiary legally qualifies for a particular enrollment or Guaranteed-Issue right.

How Should I Run the Non-Renewal Conversation?

Start with the official notice.

Confirm:

The exact plan that is ending.
The coverage termination date.
Whether the beneficiary has received any additional carrier communications.
The beneficiary’s doctors and specialists.
Current prescriptions.
Pharmacy preferences.
Other health coverage.

Then explain the available paths without ranking them before understanding the beneficiary’s needs.

Depending on eligibility and timing, a beneficiary may consider:

Enrolling in another Medicare Advantage plan
Returning to Original Medicare
Adding a stand-alone Part D plan when appropriate
Applying for a Medigap policy if Guaranteed-Issue or other enrollment rights apply

If the beneficiary takes no action and the Medicare Advantage plan terminates, the beneficiary may be returned to Original Medicare.

That does not mean the person automatically receives Medigap or stand-alone Part D coverage.

How Do Medigap Guaranteed-Issue Rights Work After a Plan Non-Renewal?

A Medicare Advantage plan non-renewal may create a federal Medigap Guaranteed-Issue right when the beneficiary returns to Original Medicare.

The timing is important.

For qualifying situations, Medicare allows the beneficiary to apply for Medigap:

Beginning 60 days before Medicare Advantage coverage ends
Through 63 days after the coverage ends

For a Medicare Advantage plan ending December 31, 2026, the beneficiary may therefore be able to begin the Medigap application process before the end of the year.

The beneficiary generally must switch to Original Medicare to use the applicable Medigap Guaranteed-Issue right.

Medigap coverage cannot begin while the beneficiary remains enrolled in Medicare Advantage.

Keep the non-renewal or termination notice because the Medigap carrier may require documentation showing that the prior coverage ended. Medicare confirms this 60-day-before / 63-day-after framework for qualifying Guaranteed-Issue situations.

Which Medigap Plans May Be Available Under Guaranteed Issue?

Do not tell every client that every Medigap plan is available under GI.

The applicable plans depend on Medicare eligibility date and state rules.

In Texas, TDI explains that beneficiaries who first became eligible for Medicare before January 1, 2020 may have GI access to Plans A, B, C, F, K, or L, while those first eligible on or after January 1, 2020 may have GI access to Plans A, B, D, G, K, or L, subject to the applicable qualifying event.

Agents should verify:

The beneficiary’s original Medicare eligibility date
The reason coverage is ending
Current federal GI rules
Texas requirements
The Medigap carrier’s documentation requirements

Do not promise issuance until eligibility has been confirmed.

What Is the Non-Renewal Special Enrollment Period?

CMS provides a Special Enrollment Period for individuals whose Medicare Advantage or Part D plan is non-renewed effective January 1.

For a plan ending December 31, 2026, the non-renewal SEP runs:

December 8, 2026 through February 28, 2027.

CMS’s 2027 enrollment guidance confirms that:

Elections made December 8–31 generally take effect January 1.
Elections made in January generally take effect February 1.
Elections made in February generally take effect March 1.

This SEP gives affected beneficiaries additional time after AEP to select eligible Medicare Advantage or Part D coverage.

How Does the Non-Renewal SEP Fit With AEP?

The two enrollment opportunities overlap operationally but serve different purposes.

October 15–December 7: Medicare Open Enrollment

Affected beneficiaries can review available 2027 options and make an eligible election during AEP.

If the beneficiary selects new coverage during AEP, that election generally begins January 1.

December 8–February 28: Non-Renewal SEP

A beneficiary affected by a January 1 non-renewal who did not complete a replacement election during AEP has an additional enrollment opportunity.

Medicare.gov confirms that this SEP is available between December 8 and the last day of February following the plan year in which the non-renewal occurs.

Do not describe the SEP as an unlimited extension of AEP.

Use the SEP according to the specific non-renewal rules and document which enrollment period supports the election.

How Should Agents Handle Clients Who Want Original Medicare and Medigap?

Treat the Medigap and Medicare enrollment pieces as related but separate.

Confirm:

The Medicare Advantage termination date.
The beneficiary’s return to Original Medicare.
Whether a Guaranteed-Issue right applies.
Which Medigap plans are available under that right.
The Medigap application deadline.
Whether stand-alone Part D coverage is needed.

Do not wait until the last week of the 63-day period to begin the Medigap discussion.

For qualifying cases, the application window may begin 60 days before Medicare Advantage coverage ends.

Texas also has its own Medicare Supplement rules, including guaranteed-issue standards under 28 TAC §3.3312.

What Compliance Rules Apply to Non-Renewal Conversations?

A non-renewal does not suspend Medicare marketing requirements.

Scope of Appointment

The Scope of Appointment requirement remains applicable to personal marketing appointments when required.

For CY2027, CMS removed the mandatory 48-hour waiting period between the SOA and the appointment.

The removal of the waiting period does not eliminate the SOA requirement.

TPMO Disclaimer

Use the current approved TPMO disclaimer when applicable.

Do not reuse an older disclaimer simply because it was approved in a previous year.

Call Recording

Follow the current CMS, carrier, and organizational requirements for applicable Medicare sales and marketing calls.

For CY2027, the federal retention framework changed to six years for applicable recorded sales and marketing calls.

Agents should still follow any stricter carrier or organizational procedure that applies.

Plan Representation

Do not imply that you represent every plan or carrier in the market unless that statement is factually true.

Use the current approved disclosure language.

Steering

Do not recommend a plan because:

It pays a higher commission
It is easier to submit
The carrier is preferred internally
The enrollment system is more convenient

Recommendations should be based on beneficiary needs and the plans the agent is permitted to discuss.

How Should Referrals Be Handled?

A beneficiary affected by a non-renewal may tell friends or family members about an agent who helped them.

That does not automatically give the agent permission to call those individuals.

A safer workflow is:

Give the existing client your contact information.
Let the client share that information.
Have the referred person initiate contact.
Document permission to contact when required.

Do not treat a name or phone number supplied by an existing client as automatic permission for an unsolicited Medicare marketing call.

What Should Agents Track in the CRM?

For confirmed non-renewal clients, useful fields include:

Carrier
Current plan
County
Coverage end date
Notice received
Notice uploaded
Current PCP
Specialists
Prescriptions
Pharmacy
Medigap GI review
GI deadline
AEP election
Non-renewal SEP eligibility
Follow-up date
Final 2027 coverage
Documentation completed

OmniReach can be configured to help agents track these items.

Automation can help prevent missed follow-ups, but the agent still needs to verify eligibility, coverage dates, enrollment rules, and carrier documentation.

A Practical Non-Renewal Workflow

September 2026: Prepare

Segment MA and MAPD clients by carrier and county.
Build a watchlist using official carrier information.
Review current CMS guidance.
Prepare compliant client-service scripts.
Confirm SOA and TPMO workflows.
Prepare CRM fields for confirmed non-renewals.
Do not label a client as confirmed until official information supports it.

Early October: Confirm

As official non-renewal notices arrive:

Confirm the affected plan.
Upload or save a copy of the notice.
Verify the coverage end date.
Move the client from watchlist to confirmed non-renewal workflow.
Update providers and prescriptions.
Schedule the appropriate review.

October 15–December 7: AEP

For affected clients:

Review eligible replacement options.
Verify provider networks.
Review prescriptions and formularies.
Discuss Original Medicare when appropriate.
Review potential Medigap GI rights when applicable.
Complete required compliance documentation.
Document the beneficiary’s election.

December 8–December 31

For clients who have not completed an election:

Review non-renewal SEP eligibility.
Continue applicable Medigap GI work.
Confirm January 1 coverage arrangements.
Identify beneficiaries who may otherwise return to Original Medicare without separate prescription coverage.

January–February 2027

Continue monitoring clients eligible for the non-renewal SEP.

Remember:

January elections generally become effective February 1.
February elections generally become effective March 1.
Medigap Guaranteed-Issue deadlines may expire before the non-renewal SEP ends.

These are separate clocks.

Track them separately.

Do Not Treat the 63-Day GI Period and the SEP as the Same Deadline

This is one of the most important operational points.

The Medigap Guaranteed-Issue period and the Medicare Advantage/Part D non-renewal SEP are not the same thing.

A beneficiary could still be inside the non-renewal SEP while approaching or passing a Medigap GI deadline.

For qualifying Medigap GI cases, Medicare generally permits application from 60 days before the current MA coverage ends through no more than 63 days after it ends.

The non-renewal SEP, by contrast, runs from December 8 through the last day of February for January 1 non-renewals.

Agents should track both dates independently.

Where TMS Insurance Brokerage Fits

TMS Insurance Brokerage helps independent Medicare agents build repeatable workflows for complex enrollment situations.

Agent resources include:

OmniReach CRM
Dedicated Agent Success Manager support
Medicare-focused training
Carrier contracting support
Medicare Agent IQ education
Qualifying Brokerage Bucks marketing support

For a non-renewal workflow, OmniReach can help agents separate watchlist clients from confirmed non-renewals, track important dates, organize documentation, and schedule follow-up through February.

The technology supports the process.

It does not replace the agent’s responsibility to verify Medicare rules, carrier notices, Medigap eligibility, provider information, and enrollment requirements.

A Clean Workflow Protects the Client and the Book

A Medicare Advantage non-renewal is stressful when nobody knows what happens next.

It becomes manageable when the agent separates the process into clear steps:

Confirm the official non-renewal.
Verify the coverage termination date.
Review providers, prescriptions, and beneficiary priorities.
Explain available Medicare paths without steering.
Check applicable Medigap Guaranteed-Issue rights.
Track the GI deadline separately from the non-renewal SEP.
Complete the beneficiary’s eligible election.
Document the process.

The agents who handle non-renewals well will not necessarily be the agents making the most calls.

They will be the agents with accurate information, clean documentation, clear deadlines, and a repeatable system.