Medicare AEP Readiness Checklist for the Final Two Weeks
AEP opens October 15. Here is a day-by-day checklist for a small Medicare agency: certifications, licenses, Scope of Appointment, the TPMO disclaimer, templates, and staffing, with the two CMS rule changes that affect this year's process.
Medicare's Annual Enrollment Period opens October 15 and runs through December 7, the one federally set window when most beneficiaries can change plans. With a little over a week left, "ready" isn't a feeling — it's a specific, checkable list: certifications filed, appointments current, compliance paperwork set up the way this year's rules require, your book triaged, and your team scheduled. This AEP readiness checklist lays that list out by how many days you have left. It's written for a small or independent agency — a handful of writing agents, maybe a CSR, no dedicated compliance department — where readiness is whatever the owner or office manager personally checks before October 15. If that's a bigger team with a downline, every item still applies; it just gets assigned to more people instead of done by one. What Changed for This AEP — Handle These First Two rule changes landed before this AEP opens, and both affect how your agency documents a sales conversation. CMS's Contract Year 2027 Medicare Advantage and Part D final rule, issued April 2, 2026, includes a provision removing restrictions on the time and manner by which beneficiaries can have conversations with licensed agents and brokers . In practice, that's the rule everyone has been calling the "48-hour Scope of Appointment rule" — the fixed waiting period between signing an SOA and holding a personal marketing appointment is gone, though a Scope of Appointment still has to be secured and documented before that appointment happens under 42 CFR 422.2274 . The current regulatory text for the TPMO disclaimer at 42 CFR 422.2267(e)(41) also no longer ties the disclaimer to the first minute of a call — it has to be conveyed verbally before any discussion of benefits, which is a longer runway on intake calls but still mandatory. If your scripts, training, or vendor paperwork still reference the old 48-hour wait or a first-minute timer, that's the first thing to fix, not something to get to later. AgencyView's own Scope of Appointment record-keeping guide walks through what to document under the new timing. Days 14–10: Certifications, Appointments, and Call Setup Confirm every selling agent's AHIP and carrier certifications are complete and loaded with the carriers you're appointed with this plan year. If anyone is still mid-certification, that's a staffing problem, not a paperwork problem — reassign their pipeline now. AgencyView's AHIP certification deadlines guide has the specific dates. Check for license or appointment gaps before AEP exposes them. A lapsed state license or a carrier appointment that didn't renew is invisible until a submission bounces mid-enrollment. AgencyView pulls license and appointment status from NIPR so a lapse shows up on a dashboard instead of in a declined policy — see how license monitoring surfaces a lapse before it costs a sale . Test call recording end to end — not just that it's turned on, but that a finished call actually lands back on the right contact record. CMS requires recording of Medicare sales calls, and a recording nobody can find when a complaint comes in is the same as no recording at all. Days 9–5: Set Up the Paperwork You'll Need Mid-Call Set your agency's TPMO disclaimer and thresholds now , not while a client is on the phone. In AgencyView, the TPMO disclaimer and the number of organizations and plans you represent are configured once in AEP Review → Thresholds and then appear automatically on every client-facing review from that point forward — nobody has to remember the current wording mid-call or retype it for each client. Send Scope of Appointment requests before the appointment, not during it. A client can sign an SOA on their phone by text or email, or on a tablet handed across the desk, and the signed PDF files itself to the contact record automatically — no separate scanning or filing step to forget on your busiest week of the year. The request also tracks how the client first contacted you, which carriers and plans were discussed, and whether it was signed within 48 hours of the appointment, so a late signature has its reason on file instead of a gap no one remembers explaining. Load this year's text and email templates rather than writing them live during a call, and have an agent read through them once for tone and accuracy before the first real client sees one. Clean up duplicate contacts and incomplete households now. A duplicate record splits a client's call history, medications, and prior plan notes across two entries, and nobody notices until a reviewer is looking at half the picture mid-call. This is a five-minute pass per agent today; it's a client complaint during AEP week if it waits. Days 4–1: Triage the Book and Lock the Schedule Decide who gets called first. Clients with upcoming Part D formulary changes, a dropped provider, or a plan leaving the market need a call before October 15, not after. A straight alphabetical dial list wastes your best week on clients who don't need to hear from you yet. Publish the on-call and after-hours schedule before AEP opens, including who answers plan-comparison questions if the primary writing agent is unreachable, and who's authorized to send an SOA or a disclosure on short notice. Walk a new or newly-certified agent through one full mock call — TPMO disclaimer, SOA, plan comparison, recording — so the first time they do it for real isn't also the first time they do it at all. If you manage a downline, confirm every agent under you has done the same four items above. A hierarchy is only as ready as its least-ready agent, and AEP week is a bad time to discover one of them skipped the mock call. Day 1 and the Weeks After: What to Watch Once AEP Is Live Spot-check SOA documentation daily for the first week. The waiting period is gone, but an SOA still has to exist and be dated before the appointment — a missing one is now a process failure, not a timing one. Confirm the TPMO disclaimer is actually being read before benefits come up, especially on calls handled by newer agents who may still be used to the old first-minute habit. Watch the enrollment pipeline, not just the call count. A spike in calls with no matching rise in submitted applications usually means a bottleneck downstream — in carrier portals, in paperwork, or in a step nobody assigned to anyone. Set a standing weekly review for the length of AEP — call volume, SOA completion, pending submissions, and anything a license or appointment check flagged — rather than waiting for December 7 to find out where the weeks went. The AEP Readiness Checklist at a Glance Window Do this Why it matters now 14–10 days out Certifications current, licenses/appointments checked, call recording tested These are invisible until a submission or an audit exposes the gap 9–5 days out TPMO disclaimer and thresholds set, SOA process ready, templates loaded, data cleaned No time to build these live once calls start 4–1 days out Book triaged, staffing schedule published, mock call run October 15 is the wrong day to improvise Day 1 onward Spot-check SOA timing, confirm disclaimer habits, watch the pipeline New rules change old habits slower than they change the regulation FAQ When does Medicare AEP start and end this year? October 15 through December 7, the same federally set window every year, per Medicare.gov . Do I still need a Scope of Appointment before a personal marketing appointment? Yes. What changed is the fixed 48-hour wait between signing it and holding the appointment — that requirement was removed in CMS's Contract Year 2027 final rule. The SOA itself still has to be secured and documented before the appointment under 42 CFR 422.2274 . Does the TPMO disclaimer still have to be read in the first minute of a call? No — the current rule requires it be conveyed verbally before any discussion of plan benefits, which isn't the same as a fixed one-minute timer. It's still mandatory on every applicable sales call. How far ahead should a small…
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