A storm is coming. Marketing dollars are drying up. Carriers are tightening. Seniors are confused. CMS just locked the 2027 rules. Some help us, some hurt, and none of them are slowing down. We don't get to wait this one out. We prepare now, or we get caught flat-footed in October.
This is the first time we've sat down together, with sales, ops, leadership, and finance in the room, and built the AEP plan on purpose, this far in advance. We did this because last year was volatile, and the next one is going to be harder. The good news is we have time. It's only May. If we use Q2 right, September won't surprise us.
2026 wasn't a loss. We grew. We didn't grow the way we wanted, 4% against a 25% goal, but we held our ground in a market that was actively moving against agents. Humana carried us. Events worked. Seminars were the most organized they've ever been. The team showed up before AEP ready to sell, which is something I haven't seen happen here before.
We also lost ground. We lost three top producers and didn't replace them. Recruiting stalled. Connecture broke at the worst possible time. Spark didn't deliver the volume we built our budget around. And mid-November, we went from on fire to nosediving in a way I've never seen before. Some of that was the market. Some of it was us. Both have to be addressed.
That verse has been on my mind since the planning meeting. It's the right posture for this season. We tighten up. We don't cut corners. We cut excess. We get sharper. We watch every dollar, every relationship, every process. We don't survive 2027 by hoping the carriers come back to us. We survive it by building something that doesn't depend on them.
Since our planning session, CMS has finalized the Contract Year 2027 Rule. There's good news in it for us, and there's news we have to plan around. I've built the relevant pieces of that rule directly into this document so we can see exactly how it lands on our business. Read it. Push back on it. Own your piece of it.
We're still here. We're still growing. And we have a real shot at making 2027 the year we stopped depending on the storm to die down and started building something the storm can't take from us.
Medicare grew, but well below target. AEP itself ran 46 enrollments behind 2025, almost a flat finish on the highest-volume window of the year. The full year shows the same pattern: We started the strongest we've ever been, then mid-November the wheels slowed.
Humana didn't just win. Humana plus the other top three combined came within 200 sales of each other. C-SNP dominated the plan mix.
We lost Lana, Joe, and JC in 2026 and didn't replace them. Conservatively, that's ~1,200 AEP enrollments we left on the table. To put that in context: we missed our growth budget by roughly 2,100 enrollments. Recruiting alone could have closed more than half the gap. This is the single most fixable miss of the year.
The Final Rule (CMS-4208-F3 / CMS-4212-F) was published April 6, 2026. Effective June 1, 2026. Marketing rules apply to all CY 2027 marketing starting October 1, 2026. We need every agent, manager, and AP partner clear on these eight provisions before pre-AEP training kicks off.
CMS eliminated the 12-hour delay requirement. Plans and agents can now hold a marketing event directly following an educational event in the same location, as long as the beneficiary is notified that the event type is changing and given a chance to leave (a brief restroom or snack break qualifies).
This is a real win. Our 350+ community events and seminars get more efficient. We can run an educational event and convert directly into a marketing appointment same day, same location. No more sending seniors home to come back later. Logistics get easier, agents get more done, and the senior has a better experience. Build this into our Q3 event playbook and train every event-running agent on the new flow.
CMS eliminated the requirement that an SOA had to be collected at least 48 hours before a personal marketing appointment. An SOA is still required, just no longer with a fixed waiting period. The beneficiary can complete the SOA and meet right away to discuss plan products.
Big practical win. Our agents who travel, especially in Georgia, North Carolina, and the outer Florida markets, no longer have to make two trips. Walk-ins can convert same-day. Phone leads don't go cold waiting two days. This is one of the biggest rule wins of 2027 and directly supports our recruiting pitch: HPM agents can move faster than the competition because the regulation is finally on our side.
Two changes. (1) The TPMO disclaimer no longer has to be read in the first minute of the call. Instead, it must be read "prior to the discussion of any benefits." (2) SHIPs are removed as a referral source from the disclaimer; only Medicare.gov and 1-800-MEDICARE remain.
Better call flow. Agents can collect demographics, confirm eligibility, and screen the call before reading the disclaimer. That puts the disclaimer where it belongs, right when the senior is about to hear plan benefits, instead of cold off the top. Update every call script, every recorded-call protocol, and every TPMO-style training before October 1, 2026. Also pull SHIP language out of every existing script and material.
CMS removed the word "scheduled" from the SOA requirement. An SOA is now required for any personal marketing appointment, no matter who started it: outbound calls, inbound calls, walk-ins, web chats, online forms. In-person appointments require a written SOA.
Compliance tightening. We can't rely on the old "walk-in exception" mindset. Every agent now needs an SOA workflow that handles unscheduled inbound contact, both in-office walk-ins and inbound phone and web. This is the kind of detail that creates audit exposure if we miss it. Build it into the compliance training, the office walk-in script, the website lead intake, and every call center workflow. Single biggest operational compliance change in the rule.
CMS codified that four specific SEPs (contract violation, CMS sanction, loss of creditable coverage notification, and "exceptional circumstances") now require CMS approval before any election can be transmitted by an MA or Part D plan. The beneficiary must go through 1-800-MEDICARE or the OEC. Agents and brokers can still assist, but the election has to flow through CMS first.
Process change for edge-case SEPs. When an agent encounters a senior with one of these four scenarios, the path is now: assist them to call 1-800-MEDICARE, get the SEP approval, then complete the election. Train Lina, Al, Victor, Arlene, and the producer base on the new flow so we don't have rejected enrollments showing up in November. Doesn't impact our high-volume SEPs, but creates real friction on the long tail.
In the original strategic plan, we flagged the proposed provider-termination SEP as an opportunity (the rule that would have given a member an SEP if their PCP dropped a plan). CMS did not finalize it. They acknowledged broad interest and said they'll "continue to consider" future rulemaking, but it's not in the 2027 rule.
Removes one of our retention levers. We had this as an opportunity in the original SWOT. It's off the table for 2027. If we want to manage churn from PCP drops, we have to do it the old-fashioned way: book-of-business analysis, proactive outreach, and provider-partner alignment. That makes Pillar 04 (bunkering with provider partners) more important, not less. It also reinforces the case for HQ-driven retention analytics.
Three changes inside one provision. (1) MA plans must post their objective SSBCI eligibility criteria on a public-facing website annually. (2) Debit/flex card administration is now codified: real-time verification of purchases, more disclosure, alternate reimbursement. (3) Cannabis products (including hemp-derived) banned as SSBCI. Notably, CMS did not finalize the proposed prohibition on marketing the dollar value of supplemental benefits, so agents can still talk about flex card amounts.
Mostly neutral, partly positive. Public SSBCI eligibility criteria means agents can verify chronic-condition qualification without playing phone tag with the carrier, which helps closing speed. Flex card guardrails will create some friction for seniors at the register (real-time verification can fail), so agents need to set expectations during enrollment. The cannabis ban is a non-issue for our market. Most importantly, we can still market the dollar value of flex and food card benefits. That is how this category gets sold.
CMS finalized changes to the Star Ratings program. The Health Equity Index reward (also called Excellent Health Outcomes for All) is not moving forward. The historical reward factor stays. Several measures are being removed. Most measure removals apply to the 2027 measurement period and 2029 Star Ratings; a few apply earlier.
Indirect impact. Star Ratings hit carrier revenue, which feeds back into bonus payments, plan benefits, and how aggressive carriers can be in our market. Net of all these changes, the Medicare Trust Fund keeps $18.56B over ten years. In plain terms, less carrier upside from Stars, which compounds the marketing co-op pressure we're already seeing. It doesn't change our operations directly, but it reinforces why we can't count on carrier marketing dollars in 2027 the way we did in past years.
Updated post-Final Rule. Two opportunities removed (provider-termination SEP) and three new opportunities added (12-hour rule, 48-hour SOA, TPMO timing). Hover over any card to focus.
What we proved we can do.
What we have to fix.
What we can build that nobody else is.
What's coming whether we're ready or not.
Filter by severity. Updated to reflect the CMS Final Rule. Click any row to focus.
If a project can't trace back to one of these six, we shouldn't be spending Q2-Q4 2026 on it. This is how we keep focus when the urgent tries to crowd out the important.
We have to refill the seats we lost and protect the ones we have. Direct-agent-first; agency partners stay important but stop being our primary growth lever. Independence from any single channel is the goal.
Carrier marketing dollars aren't coming back the way they were. We need our own lead generation, our own content, our own data. Assets that don't disappear when a carrier changes its mind in March.
Ancillary is 3% of our sales and could be 15% without changing anything except agent awareness and process. Add ICHRA, life, and ACA cross-sell, and every product line we add is a buffer against Medicare turbulence.
Provider-termination SEP did not pass. That makes our provider-partner relationships more important, not less. Without that SEP lever, retention happens through deep alignment with the docs, not regulation.
The agents who came to us prepped before AEP 2026 sold better. The CMS Final Rule adds new training requirements we cannot miss. Every agent and AP needs the new SOA, TPMO, and event-flow rules cold by October 1.
The 1 Corinthians posture. We don't cut what makes us special, but we cut excess. The SOA expansion alone forces us to standardize what should have been standardized years ago.
Calibrated to the CMS Final Rule timeline. October 1, 2026 is the hard wall. Every marketing change has to land before that date.
P1 = mission critical, do not slip. P2 = important, ship in window. P3 = high upside, ship if capacity. Search or filter the list below.
| Initiative | Pillar | Owner | Target | Priority |
|---|---|---|---|---|
Compliance overhaul before Oct 1SOA workflow rebuild (walk-in, phone, web), TPMO disclaimer rewrite, SHIP removal across materials | 06 Tighten Ship | Compliance + Mike | Oct 1, 2026 | P1 |
CMS Final Rule training moduleSOA expansion, TPMO timing, event-flow change, SEP approval process: agent + AP | 05 Train | Mike + Sergio | Q3 2026 | P1 |
Recruiting funnel rebuildDirect-agent focus, pipeline reviewed weekly, KPIs reset | 01 Recruit / Retain | Sergio + Recruiter | Q2 2026 | P1 |
Referral program revampMove beyond $300: model dollars that actually move the needle | 01 Recruit / Retain | Justin + Sergio | Q2 2026 | P1 |
Owned lead system build100-landing-page model evaluated; vendor decision; pilot launch | 02 Demand Engine | Justin + Mike | Q2 2026 | P1 |
Ancillary disruption-match engineAuto-flag MA members for hospital indemnity, dental, vision based on plan profile | 03 Diversify Revenue | Mike | Q2 2026 | P1 |
UH-1 barrier-to-entry reformEliminate or restructure upfront fee; agent-friendly bonus path | 03 Diversify Revenue | Liam + John | Q2 2026 | P1 |
Provider partner alignment summitTop 3-5 partners (Innovage, Ferramed, Dedicated, others) for a same-page meeting | 04 Bunker | Sergio + Justin | Q2 2026 | P1 |
Sales trends in Monday call + HQTop carriers, top plans, weekly rundown: make industry intel visible | 06 Tighten Ship | Lina + Mike | This Monday | P1 |
Pre-AEP training wave3+ weeks before kickoff. Same playbook that worked in 2026, plus Final Rule module. | 05 Train | Mike + Sergio | Sept 2026 | P1 |
Combined event format playbookUse the 12-hour rule: educational to marketing, same location, same day | 05 Train | Sergio + Lina | Q3 2026 | P2 |
Walk-in SOA workflow + toolingIn-person written SOA capture, web form, inbound call script | 06 Tighten Ship | John + Compliance | Q3 2026 | P2 |
Agent appreciation automationEvery agent who writes a policy gets thanked. 12 thank-yous a year minimum. | 01 Recruit / Retain | Mike | Q2 2026 | P2 |
Standard 8x/year client cadenceBirthday card, check-in, cross-sell: every product, not just Medicare | 06 Tighten Ship | Mike + Marketing | Q2 2026 | P2 |
Mid-DA → Top-DA development systemLaunch kit, 1-on-1 cadence, business plan template | 01 Recruit / Retain | Sergio + Mike | Q2-Q3 2026 | P2 |
Agency partner mastermindConvert passive 60% to managed 60%; production goals; monthly accountability | 04 Bunker | Arlene + Justin | Q3 2026 | P2 |
Personal branding program for agentsWebsites, Google presence, social: agents stop being just "agents" | 02 Demand Engine | Marketing + Mike | Q3 2026 | P2 |
ICHRA partner + training programLock primary partner; build curriculum; identify target markets | 03 Diversify Revenue | Victor + Justin | Q3 2026 | P2 |
Mid-AEP energy interventionFormat that prevents the November dive. Respect agent time. | 05 Train | Justin + Sergio | Q3 2026 (design) | P2 |
Osceola office + training academyNon-negotiable: physical site must include a learning space | 05 Train | Sergio + Justin | Q2 decision · Q3 open | P2 |
Newsletter expansion (recruiting top-of-funnel)Reach prospective agents in target markets: Tampa, Atlanta, Charlotte | 01 Recruit / Retain | Marketing | Q2-Q3 2026 | P2 |
AI appointment-setter / nurtureAEP rebooking from existing book; nurture across products | 02 Demand Engine | Mike | Q2-Q3 2026 | P2 |
EDE / Connecture alternative evaluationService must match cost. Pilot one alternative. | 06 Tighten Ship | John + Mike | Q2 2026 | P2 |
SSBCI public eligibility lookupBuild a workflow that pulls each carrier's published criteria for fast C-SNP qualification | 03 Diversify Revenue | Mike + Victor | Q3 2026 | P2 |
Florida Blue secondary agencyCapture ACA market share where Blue still dominates | 03 Diversify Revenue | Justin + Sergio | Q3 2026 | P3 |
Hispanic agency / Miami expansionStandalone build with Spanish-first leader, training, and physical office | 03 Diversify Revenue | Justin | 2027 plan window | P3 |
Georgia + North Carolina expansionTrend data shows growth; sandwich strategy from Florida base | 02 Demand Engine | Sergio | Q3-Q4 2026 | P3 |
Doctor / provider HQ portalLimited-view profile so partners see their numbers: no other FMO offers this | 04 Bunker | Mike | Q4 2026 | P3 |
Scorpio engagementAEP motivational + business coaching | 05 Train | Sergio + Justin | Decision Q2 | P3 |
30-day release policy reviewProtect onboarding investment without breaking culture | 01 Recruit / Retain | Justin + HR | Q2 2026 | P3 |
Real possibilities that aren't part of the plan yet. Click to expand the detail. Revisit each as the year unfolds.
CMS explicitly stated they did not finalize this proposal but "will continue to consider the extent to which it may be appropriate to engage in future rulemaking in this area." This is one to watch closely. If it comes back in the CY 2028 proposed rule, our retention strategy gets a major tool back.
CMS Final Rule § I.DRumored on the chopping block. If it resolves, expect plan disruption and member migration. We need a contingency for affected members and an accelerated cross-sell list ready to go.
Proposed expansion beyond age 27 could open a new ACA segment. Watch for finalization and product rollout. Could combine well with the Florida Blue secondary agency play.
Considered but unlikely for next year. Would change ACA operations meaningfully if it moves forward. Continue tracking through state legislative calendars.
Carriers signaling more specialized ACA products in coming cycles. Possible niche play if products land in our markets. Combine with our existing C-SNP/D-SNP expertise.
Several commenters in the rulemaking pushed CMS to eliminate the entire TPMO disclaimer for independent agents who represent all plans in a service area. CMS didn't act this cycle but acknowledged the concern. Watch for movement in CY 2028 rulemaking.
CMS Final Rule preamble · TPMO discussionWe don't survive 2027 by hoping the storm dies down. We survive it by tightening up. We keep what makes us different, cut what doesn't earn its keep, and build what nobody can take from us.
The Final Rule gave us a few real wins and one genuine compliance lift. Treat both seriously. The wins don't sell themselves, and the compliance work doesn't do itself. October 1 is the wall. Let's clear it together.