CMS Releases CY 2027 Medicare Advantage and Part D Enrollment Guidance: Five Changes Plans Must Address Before January 1

CMS released the CY 2027 Medicare Advantage and Part D Enrollment and Disenrollment Guidance, appendices, and exhibits on August 25, 2026.

While the release is effective January 1, 2027, the operational requirement is tied to the enrollment effective date:

“All enrollments with an effective date on or after January 1, 2027, must be processed in accordance with the revised requirements.”

Enrollment requests received during the 2026 Annual Enrollment Period for a January 1 effective date must be processed under the revised guidance.

Key changes for health plans and their delegated partners include:

• Enrollment forms: The model enrollment forms now display an OMB expiration date of February 28, 2029, replacing the December 31, 2026 date. Plans should inventory every enrollment channel, including paper, web, electronic enrollment platforms, agents and brokers, field sales, and downstream vendors.

  
  

• Paper form availability: Plans must make a paper enrollment form available upon request and provide a downloadable form on their website. An electronic enrollment portal does not replace the downloadable-form requirement. Plans must also accept paper enrollment requests received in person, by mail, or by fax.

  
  

• MA enrollment capacity limits: The revised guidance reinforces that capacity restrictions should be addressed through the annual bid process as outlined in the “Final Contract Year 2027 Standards for Part C Benefits, Bid Review and Evaluation” from April 22, 2026. Under 42 CFR § 422.254(c)(4) and (e)(1), an MA organization may establish an enrollment capacity limit for one or more MA plans as part of its bid submission.

  • An organization that did not establish a capacity limit through the bid process may not later restrict enrollment for capacity reasons unless it requests and receives CMS approval under 42 CFR § 422.60(b). CMS will consider an out-of-cycle request only when beneficiary health and safety are at risk.

  • The guidance also clarifies the operational requirements after an approved limit is reached:

    • Valid enrollment requests must be processed in the order received until the capacity limit is reached.

    • Requests received before the limit was reached must continue to be processed, even if the plan identifies that it has reached capacity later that day.

    • Requests received after the capacity limit was reached must be denied.

    • The plan must remain closed to all prospective enrollees until space becomes available through natural attrition.

    • The organization cannot selectively reopen enrollment for particular applicants, channels, or populations.

    • This is distinct from a plan that is closed to OEP or OEPI enrollment. In that situation, the organization may either deny enrollment requests or place applicants on a waiting list, but it must apply the selected approach consistently to all affected requests. CMS also added related denial reasons to MA Exhibit 7.

  • For bid, compliance, and enrollment leaders, this creates an important planning decision: anticipated capacity constraints should be evaluated and documented during bid development. Waiting until enrollment pressure emerges substantially narrows the available path because an out-of-cycle capacity request must meet CMS’s beneficiary health-and-safety standard.

• Integrated D-SNP passive enrollment: New MA Exhibits 40 and 41 establish 60-day and 30-day notices for individuals CMS passively enrolls from one integrated D-SNP into another to preserve integrated care. CMS will provide specific processing and notice instructions directly to affected organizations.

  
  

• Termination or modification SEP: The SEP for individuals whose plan or contract is terminated or modified by an MA organization, Part D sponsor, or mutual consent now extends through two months after the month of termination, rather than one month.

  
  

• D-SNP eligibility operations: CMS clarified when deemed continued eligibility begins and confirmed that deeming does not apply to individuals erroneously enrolled in a D-SNP. If the state determines before the effective date that an applicant does not meet state eligibility requirements, the plan must submit an enrollment cancellation immediately.

  
  

• CMS-approved SEPs: The guidance expressly states that several SEPs require prior CMS approval and that individuals must call 1-800-MEDICARE. These include SEPs involving inadequate notice of loss of creditable coverage, contract violations, CMS sanctions, and other exceptional circumstances.

  
  

• Additional Updates: The release also updates the definition of a “lawfully present individual,” Medigap guaranteed-issue information, default enrollment notices, loss-of-D-SNP-status notices, and requirements related to disruptive-behavior disenrollment requests.

  
  

This is not simply a form and notice update. It requires coordinated decisions across bid development, enrollment operations, compliance, sales distribution, digital channels, IT configuration, training, and delegated-entity oversight.

Our team is helping organizations translate the CY 2027 changes into actionable requirements, assess operational gaps, update enrollment materials and procedures, and validate readiness across internal and delegated enrollment channels.

If your CY 2027 readiness plan does not yet connect bid decisions with enrollment operations, now is the time to close that gap.

Contact Rebellis Group to schedule a focused CY 2027 enrollment readiness assessment.

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