CMS Contract Year 2027 Medicare Final Rule: Broker Guide

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Published: 03.05.2026

What is the CMS Final Rule?

The CMS Final Rule is a regulation issued by the Centers for Medicare and Medicaid Services (CMS) that updates and clarifies policies pertaining to Medicare Advantage, Medicare Part D, Medicare Cost Plans, and other CMS-related programs.

Contract Year 2027 Medicare Advantage and Part D Proposed Rule (CMS-4212-P)

On November 25, 2025, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule that would revise the Medicare Advantage (MA) Program, Medicare Prescription Drug Benefit Program (Part D), and Medicare Cost Plan Program for the 2027 contract year.

The aim of these proposed updates is to improve quality and access to care for people enrolled in these programs. Outlined below are several of the proposed Medicare changes that are important to note for health insurance agents and brokers selling Medicare Advantage and Medicare Part D.

Additionally, we encourage you to visit the full CMS CY 2027 Proposed Rule release for details.

Top Broker Focus Areas for CY 2027

What Medicare changes can brokers expect to see in 2027?

1. Marketing, Events & Scope of Appointment (SOA)

   • Removal of the 48-hour waiting period between Scope of Appointment (SOA) and a personal marketing appointment.
   • Elimination of the 12-hour gap requirement between an educational event and a marketing event at the same location when opt-out is allowed.
   • Relaxation on use of superlatives (e.g., best, most, etc.) provided materials are not misleading.

2. Third-Party Marketing Organization (TPMO) Updates

   • Revised disclaimer timing—read before discussing benefits rather than within the first minute.
   • Reducing the amount of time that MA Organizations and Part D sponsors are required to retain recordings of marketing and sales calls to 6 years, while maintaining the requirement that enrollment records and portions of calls be retained for 10 years,

3. Enrollment Process Enhancements

   • New special enrollment flexibility when a beneficiary’s key provider leaves the network, enabling midyear plan changes.
   • Codification of which SEPs require prior CMS approval to improve predictability.

4. Star Ratings Overhaul

   • CMS proposes removing 12 measures largely focused on administrative/process metrics to refocus ratings on clinical outcomes and member experience.
   • CMS does not plan to implement the Excellent Health Outcomes for All reward (previously called the Health Equity Index reward) for 2027 and will retain the historical reward factor.
   • New Part C "Depression Screening & Follow-Up" measure starting with the 2027 measurement year (impacting 2029 Star Ratings).
   • Implication for brokers: Expect plan quality shifts; emphasize outcomes and experience when advising clients.

5. Medicare Part D Redesign (IRA Codification)

   • Codifies Inflation Reduction Act (IRA) changes: elimination of the coverage gap phase and annual OOP redesign, catastrophic phase cost-sharing changes.
   • Formalizes the Manufacturer Discount Program and related benefit design updates.

6. Documentation Standards & Prescription Drug Event (PDE) Integrity

   • Strengthened requirements to retain original-format documentation (e.g., audio files) for coverage determinations.
   • Potential deletion of Prescription Drug Event (PDE) records if documentation is incomplete or altered.

7. Risk Adjustment Data Use & Release

   • CMS signals a broader ability to use and release risk adjustment data (including pre-reconciliation) to government entities and external parties, while protecting beneficiary confidentiality.

8. Special Needs Plans (SNPs)

   • Clarifications on passive enrollment mechanics for D-SNPs and flexibility for states without mandatory Medicaid managed care.
   • Heightened attention to growth trends in C-SNPs and I-SNPs via RFIs.

9. Health Equity Requirements Removed in Certain Areas

   • Eliminates specific health equity mandates in MA quality improvement programs and utilization management committees.
   • Removes public posting requirements for annual health equity analyses.

10. RFIs & Modernization Initiatives

    • CMS requests input on risk adjustment modernization, QBP timing, SNP integration for dually eligible beneficiaries, and wellness support (nutrition, social connection).
    • Focus on reducing administrative burden and modernizing marketing oversight while targeting TPMO "bad actors".

Key Dates:

• November 25, 2025: CMS releases CY 2027 proposed rule materials
• January 26, 2026: Comment period deadline for proposed rule.
• October 1, 2026: Marketing for CY 2027 begins—new marketing/TPMO rules expected to apply if finalized
• October 15, 2026 – December 7, 2026: Medicare Annual Enrollment Period (AEP)
• January 1, 2027: Contract Year (CY) 2027 Begins

What Can Brokers Do Now to Prepare?

The Medicare Annual Enrollment Period (AEP) for the 2027 plan year will be here before we know it. Don’t wait until your busiest time of year—prepare for upcoming changes to regulations and compliance before October rolls around.

• Become familiar with the proposed 2027 Medicare Advantage and Part D Proposed Rule.
• Ask questions before your clients do. If you don’t understand something, chances are your clients won’t either. Keep a running list of your questions and concerns—use this to build a FAQ and Answer Guide you can later use with clients. 
• Stay informed and educated. Be on the lookout for educational opportunities, CE courses and carrier training webinars.
• Align yourself with an expert general agency partner who can help you navigate the complexities of Medicare sales and compliance and keep you in the loop on upcoming regulatory changes.

Want to learn about working with My Savoy Benefits?

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We’ll work with you to create a customized partnership plan to make you a trusted resource for Medicare, as well as Individual and Family health plans.

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