Election Periods · 2026

Every Medicare election period — what it does, who qualifies, and how to stay compliant.

A plain-English reference chart agents actually use. Each period below includes the window, effective date, what the agent can do, what the beneficiary can do, common mistakes, and compliance watch-outs.

Educational only — see Disclaimers

What changed for 2026

  • The 48-hour Scope of Appointment waiting period is no longer required — CMS rule was vacated. SOA must still be signed before an MA/PDP sales appointment.
  • BENES Act effective dates remain in force for Part B IEP and GEP — coverage starts the 1st of the month after enrollment.
  • LIS / Dual SEP remains structured as Q1, Q2, Q3 only. No Q4 SEP — Q4 changes happen via AEP.
  • CMS continues to prohibit marketing that specifically promotes the MA OEP.
  • TPMO call-recording rule still applies to chains of enrollment for MA and PDP.

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Quick-reference chart

Period-by-period detail

InitialIEP

Initial Enrollment Period (Part A & B)

SSA & CMS — IEP / BENES Act 2023

Window

7 months — the 3 months before the month you turn 65, your birthday month, and the 3 months after.

Effective date

If enrolled before the birthday month, coverage starts the 1st of the birthday month. If enrolled in the birthday month or later, coverage starts the 1st of the month after enrollment (BENES Act, effective Jan 2023).

Who it applies to

People aging into Medicare at 65, or qualifying via disability/ESRD/ALS.

What it does

First chance to enroll in Original Medicare (Part A and/or Part B). Triggers eligibility windows for Part D, MA, and Medigap.

Agent can

  • Educate on Original Medicare vs. MA vs. Medigap + PDP paths.
  • Help compare standalone Part D plans (during the Part D IEP).
  • Quote Medigap during the Medigap OEP that opens at Part B effective date.

Beneficiary can

  • Enroll in Part A and/or Part B through SSA.
  • Enroll in a Part D or MA plan during the overlapping IEP/ICEP.

Agent tips

  • Start the conversation 4–6 months before age 65 — gives time for SOA, comparisons, and SSA processing.
  • Confirm whether they are still on employer coverage to avoid duplicate premiums.
  • Document creditable coverage to avoid Part D late enrollment penalty (LEP).

Compliance watch-outs

  • Enrolling late in the IEP delays coverage to the next month (no more retro to birthday month).
  • Disability IEP windows are tied to the 25th month of SSDI, not age 65.

Common mistakes

  • Assuming Part B auto-enrolls for everyone — only auto for those already on Social Security.
  • Skipping Part D when no creditable coverage exists — triggers a lifetime LEP.
InitialICEP

Initial Coverage Election Period (Medicare Advantage)

CMS MCMG Ch. 2 §30.4

Window

3 months before entitlement to both Part A and Part B through the month coverage starts (same 7-month shape as IEP for most aging-in clients).

Effective date

1st of the month after enrollment, but no earlier than the Part B effective date.

Who it applies to

Newly Medicare-eligible beneficiaries enrolling in MA for the first time.

What it does

First-time election into a Medicare Advantage (Part C) plan.

Agent can

  • Complete a Scope of Appointment (SOA) before any MA/PDP discussion.
  • Submit one MA election under the ICEP.

Beneficiary can

  • Choose any MA plan they're eligible for in their service area.

Agent tips

  • ICEP runs in parallel with IEP — clarify which election you're using on the application.
  • If they delay Part B, the ICEP shifts and may collapse — re-check the window.

Compliance watch-outs

  • Only one ICEP election. Additional changes after effective date require an OEP-NEW or another SEP.

Common mistakes

  • Treating ICEP and Part D IEP as the same — they're separate windows with separate rules.
InitialPart D IEP

Part D Initial Enrollment Period

CMS Pub 100-18 Ch. 3

Window

Same 7-month shape as the IEP, but tied to Part D eligibility (Part A or Part B + U.S. residency).

Effective date

Generally 1st of the month after enrollment.

Who it applies to

Anyone newly eligible for Part D.

What it does

First-time enrollment in a standalone PDP or MAPD's drug benefit.

Agent can

  • Run a Medicare Plan Finder formulary check before recommending a PDP.
  • Document creditable coverage if delaying.

Beneficiary can

  • Enroll in any PDP or MAPD in their service area.

Agent tips

  • Always confirm pharmacy + formulary + retail vs. mail order pricing.
  • If they have creditable employer Rx coverage, get written proof for the file.

Compliance watch-outs

  • Missing the Part D IEP without creditable coverage triggers the lifetime LEP (1% of national base premium × months uncovered).

Common mistakes

  • Assuming VA or TRICARE makes Part D unnecessary forever — confirm coordination.
AnnualAEP

Annual Election Period

CMS MCMG Ch. 2 §30.2; 42 CFR §422.62

Window

October 15 – December 7 every year.

Effective date

January 1 of the following year.

Who it applies to

All Medicare beneficiaries eligible for MA and/or Part D.

What it does

Change MA plans, change PDP, switch between MA and Original Medicare + PDP, or drop drug coverage. Last submission wins.

Agent can

  • Hold MA/PDP sales appointments with a signed SOA on file (no 48-hour wait — that rule was vacated).
  • Submit unlimited elections; only the last one received by the carrier takes effect Jan 1.
  • Distribute the Pre-Enrollment Checklist (PECL) before enrollment.

Beneficiary can

  • Make as many MA/PDP changes as they want — last one received wins.
  • Return to Original Medicare and add a PDP.

Agent tips

  • Re-shop every client every year — formulary, network, and Part B givebacks shift.
  • Lead with the Annual Notice of Change (ANOC) — point out what changed in their current plan.
  • Record the call if you're a TPMO and the call discusses MA/PDP marketing, sales, or enrollment.

Compliance watch-outs

  • Submitting multiple apps the same day can confuse carrier systems — verify the final disposition.
  • Medigap is NOT changed in AEP — underwriting still applies outside Medigap OEP / guaranteed-issue.
  • TPMO call-recording rule still applies in 2026.

Common mistakes

  • Treating AEP as a Medigap window.
  • Forgetting AEP elections supersede prior AEP elections only when received in the AEP window.
OpenMA OEP

Medicare Advantage Open Enrollment Period

CMS MCMG Ch. 2 §30.2.2 & §40 marketing rules

Window

January 1 – March 31 every year.

Effective date

1st of the month after enrollment.

Who it applies to

Anyone enrolled in an MA plan on January 1.

What it does

ONE change: switch to a different MA plan, OR drop MA and return to Original Medicare (with optional PDP). Cannot be used to switch PDPs by someone on Original Medicare.

Agent can

  • Help an MA enrollee make their one allowed change.
  • Service existing clients who proactively reach out — but do not run OEP-specific marketing.

Beneficiary can

  • Switch MA → MA, or MA → Original Medicare + PDP.

Agent tips

  • Use MA OEP as a service window — fix mistakes from AEP, address network issues clients discover in January.
  • Document the reason in your CRM; it strengthens compliance posture if audited.

Compliance watch-outs

  • CMS prohibits marketing that specifically promotes the MA OEP. Respond to inquiries — don't solicit OEP-based switches.
  • Someone on Original Medicare cannot use MA OEP at all.
  • Only one election — the second submission is generally rejected.

Common mistakes

  • Sending OEP-themed mailers or social posts — explicit MCMG violation.
  • Trying to add Medigap with guaranteed issue via OEP (no — separate GI rules apply).
OpenOEP-NEW

MA OEP for new Medicare beneficiaries

CMS MCMG Ch. 2 §30.2.3

Window

First 3 months of MA enrollment for someone who joined an MA plan during their ICEP (new to Medicare).

Effective date

1st of the month after enrollment.

Who it applies to

New Medicare enrollees who used ICEP to join MA.

What it does

One additional MA-to-MA change or MA-to-Original-Medicare (+PDP) change.

Agent can

  • Reposition a new client whose first MA plan isn't a fit.

Beneficiary can

  • Make one change during their first 3 months on MA.

Agent tips

  • Schedule a 30-day check-in with every new MA client to surface issues inside this window.

Compliance watch-outs

  • Independent of the annual MA OEP — distinct rule set.

Common mistakes

  • Confusing this with the regular Jan 1–Mar 31 OEP.
OpenGEP

General Enrollment Period (Part B)

BENES Act, effective January 2023

Window

January 1 – March 31 every year.

Effective date

Coverage starts the 1st of the month after enrollment (BENES Act — no longer July 1).

Who it applies to

People who missed their IEP and don't have an SEP.

What it does

Enroll in Part A (if not premium-free) and/or Part B.

Agent can

  • Direct the client to SSA for Part B enrollment.
  • Open a parallel Part D / MA SEP that follows the GEP enrollment.

Beneficiary can

  • Enroll in Part B (and Part A if premium).
  • Use the GEP-triggered Part D SEP.

Agent tips

  • The Part D SEP for GEP enrollees runs the 3 months after the GEP Part B enrollment month.
  • Expect a Part B LEP for late enrollment — 10% per 12 months delayed.

Compliance watch-outs

  • BENES Act ended the old July 1 effective date — confirm carriers and SSA reps are using current rules.

Common mistakes

  • Telling clients coverage starts July 1 (outdated).
  • Missing the parallel Part D SEP that opens for GEP enrollees.
Special5-Star SEP

5-Star Special Enrollment Period

CMS MCMG Ch. 2 §30.4

Window

December 8 – November 30 (once per year).

Effective date

1st of the month after enrollment.

Who it applies to

Anyone in a service area with a 5-star MA, MAPD, PDP, or cost plan.

What it does

One election into a 5-star plan during the window.

Agent can

  • Recommend a verified 5-star plan available in the client's county.

Beneficiary can

  • Switch into the 5-star plan once.

Agent tips

  • Verify the star rating on the Medicare Plan Finder before promising eligibility.

Compliance watch-outs

  • You can only use this SEP one time per year and only into a 5-star plan.

Common mistakes

  • Using it to switch out of a 5-star plan (it's only for switching in).
SpecialSEP-LEC

Loss of Employer / Creditable Coverage

Window

2 months after the month coverage (or creditable Rx coverage) ends, or after notice — whichever is later.

Effective date

1st of the month after enrollment (or as elected up to 3 months out).

Who it applies to

Beneficiaries losing employer, union, COBRA, or other creditable coverage involuntarily.

What it does

Enroll in MA, PDP, or change plans tied to the coverage loss.

Agent can

  • Collect proof of prior creditable coverage to avoid LEP.

Beneficiary can

  • Enroll/change MA or PDP.

Agent tips

  • Get the loss-of-coverage letter on file — carriers may request it.

Compliance watch-outs

  • Voluntarily dropping employer coverage may not qualify — verify involuntary loss.

Common mistakes

  • Confusing COBRA with creditable Rx coverage — they're different determinations.
SpecialSEP-MOV

Permanent Move

Window

Starts the month before the move (if notified) and runs 2 full months after the move.

Effective date

Up to 3 months out, beneficiary's choice.

Who it applies to

Beneficiaries who permanently move outside their plan's service area, or into a new service area with new options.

What it does

Enroll in or change MA / PDP based on the move.

Agent can

  • Help the client elect a plan in their new ZIP.

Beneficiary can

  • Switch plans tied to the move.

Agent tips

  • Document the move date in your CRM; some carriers ask for utility bill or lease.

Compliance watch-outs

  • A snowbird trip is not a permanent move — SEP doesn't apply.

Common mistakes

  • Backdating the move to extend the SEP — fraud risk.
SpecialSEP-DST

FEMA Disaster / Emergency SEP

Window

Starts when the federal, state, or local emergency is declared, and runs 4 full months after the end date (or the related election period the client missed).

Effective date

1st of the month after enrollment.

Who it applies to

Beneficiaries who lived in (or relied on someone living in) the affected area and missed an election period because of the emergency.

What it does

Make the election they missed during another valid period (e.g., AEP, IEP, ICEP).

Agent can

  • Help the client document the missed election they're recovering.

Beneficiary can

  • Use the SEP once to make the missed election.

Agent tips

  • Check the FEMA major disaster list and your state's emergency declarations.

Compliance watch-outs

  • SEP-DST is a recovery SEP — it doesn't grant a brand-new right to switch.

Common mistakes

  • Treating it as an extra AEP for anyone in the state.
SpecialSEP-LIS / Dual

LIS / Dual Eligible SEP (quarterly)

CMS-4205-F (2024 final rule)

Window

Once per calendar quarter in Q1, Q2, and Q3. There is NO Q4 LIS/Dual SEP — Q4 changes go through AEP (2025 CMS final rule).

Effective date

1st of the month after enrollment.

Who it applies to

Beneficiaries with full LIS / Extra Help or full-benefit dual-eligible status.

What it does

One MA or PDP change per quarter (Q1/Q2/Q3).

Agent can

  • Re-shop annually and quarterly as LIS benchmarks shift.

Beneficiary can

  • Change MA or PDP once per Q1/Q2/Q3.

Agent tips

  • Confirm LIS level on MARx or BEST Available Evidence — co-pay tier matters.

Compliance watch-outs

  • Partial-dual or partial LIS clients have different SEP rights — check carefully.
  • The old monthly SEP ended; the quarterly structure has been in effect since 2025.

Common mistakes

  • Trying to use a Q4 LIS SEP — it no longer exists; use AEP.
SpecialSEP-Inst

Institutional SEP

Window

Continuous while the beneficiary lives in a qualifying institution (LTC, SNF, IRF, LTC hospital, psych hospital, rehab), plus 2 months after moving out.

Effective date

1st of the month after enrollment.

Who it applies to

Residents of qualifying institutional facilities.

What it does

Enroll in, change, or drop MA/PDP at any time while institutionalized.

Agent can

  • Help align plan with the facility's pharmacy and network.

Beneficiary can

  • Change MA/PDP at any time during residency.

Agent tips

  • Coordinate with the facility's social worker — they often hold POA documents.

Compliance watch-outs

  • Assisted living is NOT automatically institutional — confirm the facility type.

Common mistakes

  • Using SEP-Inst for an assisted living resident without verifying.
SpecialSEP-EC

CMS Exceptional Conditions SEPs

Window

Varies by trigger — typically 2 months from the event or notification.

Effective date

1st of the month after enrollment.

Who it applies to

Beneficiaries affected by plan termination, contract non-renewal, sanction, error by federal employee, plan misrepresentation, or other CMS-recognized exceptions.

What it does

Allow corrective enrollment when something outside the beneficiary's control disrupted coverage.

Agent can

  • Document the trigger event and the CMS letter, if any.

Beneficiary can

  • Enroll in or change plans to restore coverage.

Agent tips

  • Save the CMS or carrier notice — it's the audit trail.

Compliance watch-outs

  • Misrepresentation SEPs require CMS approval — don't promise eligibility.

Common mistakes

  • Assuming any plan dissatisfaction qualifies — it doesn't.
SpecialSEP-CSNP

Chronic Condition SEP (C-SNP)

Window

Once at any time after a qualifying chronic condition is verified — ends when enrolled in a C-SNP.

Effective date

1st of the month after enrollment.

Who it applies to

Beneficiaries with a CMS-defined qualifying chronic condition (diabetes, CHF, ESRD, etc.).

What it does

One-time election into a C-SNP that matches the condition.

Agent can

  • Collect a Chronic Condition Verification Form (CCVF) signed by the provider.

Beneficiary can

  • Enroll into a matching C-SNP once.

Agent tips

  • The CCVF must come back from the provider within carrier-specified timelines.

Compliance watch-outs

  • If the condition isn't verified within the window, the enrollment may be reversed.
  • Note: the once-per-month dual/LIS SEP no longer exists — see SEP-LIS/Dual.

Common mistakes

  • Promising approval before the CCVF returns.
MedigapMedigap OEP

Medigap Open Enrollment Period

Window

6 months starting the 1st day of the month the beneficiary is 65 AND enrolled in Part B.

Effective date

Per carrier — usually 1st of the month after underwriting / application acceptance.

Who it applies to

Beneficiaries 65+ in their first 6 months of Part B.

What it does

Federal guaranteed-issue period — buy any Medigap plan from any participating carrier in the state without medical underwriting.

Agent can

  • Quote Medigap across multiple carriers; carriers cannot deny or rate up for health.

Beneficiary can

  • Buy any Medigap plan available in their state, no underwriting.

Agent tips

  • Some states (CT, MA, NY, VT, CA, WA, OR, MO, ID, etc.) have additional or year-round guaranteed-issue rules — confirm state-specific law.
  • Locked-in rate class often matters more than first-year premium.

Compliance watch-outs

  • Outside this window, most states require underwriting — clients may be denied.
  • Disability-Medigap OEP rules differ by state.

Common mistakes

  • Telling under-65 disabled clients they have a federal Medigap OEP — federal rule is age 65+.
MedigapMedigap GI

Medigap Guaranteed-Issue Rights

Window

Generally 63 days from the qualifying event.

Effective date

Per carrier.

Who it applies to

Beneficiaries who lose other coverage or face a trial-right scenario.

What it does

Right to buy specific Medigap plans without underwriting after a qualifying event: MA trial right (12-month), loss of employer/union retiree coverage, plan termination, carrier bankruptcy, plan misrepresentation, move outside service area.

Agent can

  • Collect the proof letter and apply within the 63-day window.

Beneficiary can

  • Buy a Medigap GI plan from any carrier offering it.

Agent tips

  • MA trial-right #1: dropped Original Medicare for first MA → 12 months to return.
  • MA trial-right #2: first time on MA at age 65 → 12 months to drop.

Compliance watch-outs

  • GI plans are usually limited to Plans A, B, C/D/F/G, K, L — not every plan qualifies.

Common mistakes

  • Missing the 63-day clock.
SpecialPart B SEP

Part B Special Enrollment Period (Working Aged)

Window

8 months starting the month after employment OR employer group health coverage ends — whichever is first.

Effective date

Coverage can start the month after enrollment, or beneficiary can choose to delay up to 3 months.

Who it applies to

Beneficiaries who delayed Part B because of active employer group coverage based on current employment.

What it does

Enroll in Part B without an LEP.

Agent can

  • Direct to SSA; help quote MA/PDP/Medigap once Part B is effective.

Beneficiary can

  • Enroll in Part B without penalty.

Agent tips

  • The clock starts at the end of employment OR group coverage — whichever happens first.

Compliance watch-outs

  • COBRA and retiree coverage do NOT extend this SEP — it must be active-employment coverage.

Common mistakes

  • Believing COBRA preserves the Part B SEP — it does not.

Agent compliance reminders

  • • A signed Scope of Appointment (SOA) must be on file before any MA/PDP sales appointment.
  • • Only discuss products listed on the SOA — cross-selling requires a new SOA.
  • • TPMOs must record all calls related to MA/PDP marketing, sales, and enrollment.
  • • Distribute the Pre-Enrollment Checklist (PECL) before any enrollment.
  • • Do not run marketing that specifically promotes the MA OEP.
  • • Document the election period code on every application.
Sources: CMS Medicare Managed Care Manual Ch. 2, CMS Pub 100-18 Ch. 3, Medicare & You 2026, 42 CFR §422.62, BENES Act (effective Jan 2023), CMS-4205-F (2024 final rule). Rules can change; verify against current CMS guidance and your carrier's policies.

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