CMS Final Rule 2027
The CMS Final Rule was passed on April 2nd, 2026. The rule takes effect June 1, 2026, and the marketing rules apply October 1st, 2026 (before AEP).
Below are the high-level changes:
SOA changes are in. The 48-hour waiting period between collecting a Scope of Appointment and having a plan conversation is eliminated. You can also collect SOA forms at educational events now!
✅ May collect: At marketing events, in health care settings, at educational events (newly reinstated), and via BRCs/online forms/voicemail
❌ May NOT collect: During plan-initiated provider activities or activities by social workers of an I-SNP
The 12-hour buffer between educational and marketing events is gone. More flexibility in how you structure outreach and event flow.
TPMO disclaimer timing has been updated. The disclaimer must now be delivered prior to any discussion of benefits - but CMS actually defined what that means. General statements like "most MA plans include dental" don't trigger it. Discussing a specific plan's cost-sharing or EOC benefits does.
Superlatives are back. Advertising language restrictions are being relaxed - more room to highlight what makes a plan stand out.
Call recording retention drops from 10 years to 6.
For the full insights, please check out our blog:
Key dates
Date | What happens |
June 1, 2026 | Final rule takes effect |
October 1, 2026 | New marketing and communications rules apply |
Oct 15 – Dec 7, 2026 | AEP for plan year 2027 |
January 1, 2027 | Plan year 2027 coverage begins |