The 2027 Medicare ANOC Letter Playbook: What Independent Agents Should Do Before AEP

The weeks leading into Medicare Open Enrollment are one of the most important operational periods of the year for independent Medicare agents.

For the 2027 plan year, September 2026 should be used to organize existing clients, review Annual Notice of Change documents, identify non-renewals and plan changes, update provider and prescription information, and prepare compliant follow-up workflows for October.

The goal is not to turn September into an early AEP sales period.

The goal is to know your book before October 15.

Why Does the September 30 ANOC Deadline Matter?

The Annual Notice of Change, or ANOC, explains how a Medicare Advantage or Part D plan will change for the coming year.

Plans generally must ensure current members receive the ANOC by September 30.

That gives beneficiaries an opportunity to understand changes before Medicare Open Enrollment begins October 15.

For agents, the ANOC can serve as a structured client-service tool.

Instead of waiting until AEP begins, use September to:

•       Confirm the client’s current plan.
•       Identify changes disclosed in the ANOC.
•       Update medication and provider information.
•       Note questions that require current 2027 plan data.
•       Identify clients affected by plan non-renewals.
•       Schedule appropriate follow-up when the beneficiary wants additional help.

The ANOC is not a substitute for current plan documents, Medicare Plan Finder, provider directories, formularies, or carrier guidance.

What 2027 Changes Should Agents Understand?

Agents do not need to memorize every national policy change before reviewing an ANOC, but several 2027 developments are worth understanding.

Part D Premium Stabilization Demonstration Ends

CMS has announced that the voluntary Part D Premium Stabilization Demonstration will end after 2026.

For 2027, CMS announced:

•       A Part D national average monthly bid amount of $296.05
•       A Part D base beneficiary premium of $41.33

These figures are program-level measures and should not be presented as the premium an individual beneficiary will necessarily pay.

Actual premiums vary by plan.

2027 Plan Information Continues to Roll Out

CMS releases final Medicare Advantage and Part D landscape information once offerings are finalized.

Agents should distinguish between:

•       Information already finalized and released
•       Carrier preliminary information
•       Final approved plan-year materials

Do not present preliminary carrier information as final.

How Should I Structure an ANOC Review?

Use a repeatable process.

A good client review can be divided into three sections.

1. Current Plan Changes

Ask the client to have the ANOC available.

Review major changes involving:

•       Premium
•       Deductible
•       Copays and coinsurance
•       Maximum out-of-pocket amount
•       Drug coverage
•       Pharmacy arrangements
•       Supplemental benefits
•       Provider or network information disclosed in the notice

2. Client Needs Update

Ask whether anything has changed since the last review.

Ejemplos incluyen:

•       New medications
•       New specialists
•       New primary care doctor
•       Planned procedures
•       Change of address
•       Medicaid or LIS status
•       Employer or retiree coverage changes
•       Travel or residence changes

3. Follow-Up Needs

Document what requires additional verification.

Do not guess.

If current 2027 plan information is not yet available, note the question and follow up when authoritative plan-year information is available.

What Line Items Should Agents Check?

A practical ANOC checklist includes:

1.     Plan name and identifying information
2.     Monthly premium
3.     Deductibles
4.     Maximum out-of-pocket amount
5.     PCP and specialist cost-sharing
6.     Hospital and urgent-care cost-sharing
7.     Prescription drug coverage changes
8.     Pharmacy changes
9.     Supplemental benefits
10. Network-related notices
11. Plan renewal or non-renewal status

For prescription drugs, focus on the medications the beneficiary actually takes rather than reviewing an entire formulary without context.

For providers, verify specific doctors and facilities using current plan-year information when available.

How Should I Handle a Plan Non-Renewal?

A non-renewal requires a different workflow from a routine ANOC review.

First, confirm the official carrier notice.

Then document:

•       The plan that is ending
•       The effective termination date
•       The client’s current providers and prescriptions
•       Whether the client wants to remain in Medicare Advantage or return to Original Medicare
•       Whether federal or state Medigap Guaranteed Issue rights may apply

Do not describe every non-renewal as automatically creating the same Medigap right.

Depending on the specific circumstances, federal Medigap Guaranteed Issue protections may apply.

In qualifying situations, the application period can begin 60 days before Medicare Advantage coverage ends and generally extends no more than 63 days after it ends.

If the beneficiary wants to use a Medigap Guaranteed Issue right, verify the applicable federal rule, Texas requirements, and carrier documentation.

Keep the plan’s termination or non-renewal notice because the beneficiary may need it as proof.

Should Agents Compare 2027 Plans During a September ANOC Review?

Be careful.

September can be used to service existing clients, review their current-plan ANOC, gather information, document needs, and prepare for the coming plan year.

Agents should not prematurely market prospective 2027 Medicare Advantage or Part D offerings before the permitted marketing period begins.

Beginning October 1, prospective marketing for the upcoming plan year may begin, subject to CMS, carrier, and organizational requirements.

A September ANOC review should therefore focus on:

•       What the current plan says is changing
•       What the client needs
•       What questions must be answered later

Do not turn an ANOC service review into premature marketing of next year’s offerings.

What Changes for Agent Compliance on October 1, 2026?

Several CY2027 rules are important for agents.

Alcance de la Cita

The Scope of Appointment requirement remains.

However, beginning with the 2027 marketing period, CMS has eliminated the mandatory 48-hour waiting period between completion of the SOA and the personal marketing appointment.

An advance agreement is still required when applicable.

Removing the waiting period does not eliminate the Scope of Appointment itself.

Sales and Marketing Call Recordings

CMS reduced the required retention period for applicable recorded marketing and sales calls from 10 years to 6 years, effective October 1, 2026.

Under the new structure:

•       Years 1–3 must retain audio recordings.
•       Years 4–6 may retain audio or transcripts, consistent with the finalized rule.

Agents should still follow carrier and FMO procedures because organizations may have operational requirements beyond the federal minimum.

Superlative Claims

CMS’s 2027 rules allow certain superlative claims when they can be factually substantiated.

That does not mean agents can freely say:

•       “Best plan”
•       “Best benefits”
•       “Cheapest plan”
•       “Number one”

without evidence.

The supporting data must substantiate the claim, and communications may not be misleading, confusing, or materially inaccurate.

The safer operational rule remains: do not use comparative or superlative claims unless Compliance has reviewed both the statement and the supporting evidence.

TPMO Disclaimer

Use the current approved TPMO disclaimer applicable to the communication and plan year.

Do not reuse an old script simply because it was compliant in the prior year.

How Should Referrals Be Handled?

ANOC reviews can strengthen client relationships, and satisfied clients may refer family or friends.

But referrals do not remove Medicare contact restrictions.

An existing client can give another person your contact information.

A referred individual should initiate contact or otherwise provide permission for the agent to contact them when required.

Do not treat a friend’s name or telephone number supplied by an existing client as automatic permission to make an unsolicited Medicare marketing call.

A safer process is:

•       Give the current client your contact information.
•       Provide a compliant educational resource if appropriate.
•       Let the referred person contact you.
•       Document permission to contact when applicable.

How Should Agents Use OmniReach for ANOC Reviews?

OmniReach can be configured to help organize an ANOC workflow.

Useful CRM fields or tags may include:

•       ANOC received
•       ANOC reviewed
•       Non-renewal
•       Provider review needed
•       Prescription review needed
•       Follow-up after October 1
•       AEP appointment requested
•       Preferred language
•       Referral source

Automations can help agents organize follow-up.

They do not make a workflow automatically compliant.

Agents and agencies remain responsible for following CMS, carrier, TCPA, privacy, and organizational requirements.