CMS's CY 2027 Enrollment Guidance: An Operations Readiness Checklist for MA and Part D Plans

The update touches eligibility, election periods, enrollment methods, passive enrollment, D-SNP eligibility and involuntary disenrollment. Some changes reflect new requirements, while others clarify existing rules, correct examples or align the guidance with recently codified regulations.

For enrollment teams, the immediate question is not simply what changed. It is whether those changes have been translated into updated procedures, system rules, notices, training and exception-handling workflows before the new contract year begins.

What Changed in CMS's CY 2027 Enrollment Guidance?

CMS also updated the model enrollment form and several model exhibits, discussed in the readiness checklist below. Each area is covered in detail in the sections that follow.

Confirm Your Implementation Approach for AEP

The guidance document states that the update is effective beginning with Contract Year 2027 and that all enrollments with an effective date on or after January 1, 2027 must be processed in accordance with the revised requirements. Organizations may implement any new requirement early when doing so is consistent with the guidance. CMS's enrollment webpage, as of this writing, describes implementation in terms of the date a request is received: plans are expected to use the new guidance for all requests received on or after January 1, 2027, and may, optionally, use the updated guidance for AEP enrollments effective January 1, 2027.

Because AEP requests are received in 2026 for a January 1, 2027 effective date, the two descriptions can be read differently for AEP processing. Plans should confirm their implementation approach with their CMS account manager or the CMS enrollment mailbox. Operationally, teams should be prepared to apply the revised guidance during the AEP so that procedures, system rules, notices and delegated entities are aligned before coverage begins.

Here are the areas enrollment operations teams should be reviewing now.

1. Paper Enrollment Forms Remain an Operational Requirement

CMS added detail concerning the availability and processing of paper enrollment forms.

Plans must have, at minimum, a paper enrollment form available to prospective enrollees. The form must also be available for download from the plan's website. Providing an online enrollment portal does not replace the requirement to make a downloadable form available.

Plans must accept paper enrollment requests received:

• In a face-to-face interview
• By mail
• By fax

A paper request collected by an employed or contracted agent or broker is considered received by the plan on the date the agent or broker receives it. That date can affect the application date, election-period determination and processing deadline.

This deserves more attention than a simple website check. Enrollment leaders should confirm that:

• The correct form is posted and can be downloaded.
• Mail and fax intake points are monitored consistently.
• Agents and brokers transmit forms promptly.
• Receipt dates are preserved through every handoff.
• Paper requests enter the same aging and quality controls as electronic requests.
• Staff understand when a missing signature may be resolved through documented telephone verification.

CMS also addresses unsolicited paper AEP enrollment forms received from October 1 through October 14. The definition is narrower than teams often assume: to be considered unsolicited, the plan must have received the paper request directly from the applicant, not through a sales agent or broker. If anything about a pre-AEP paper request indicates agent or broker involvement, the plan must investigate. Plans and their representatives may not accept unsolicited pre-AEP enrollment requests through mechanisms other than paper.

For requests that qualify, the plan must retain and process them under the procedures in the guidance: a written acknowledgment within seven calendar days of receiving a complete request, and submission to CMS systems on the first day of the AEP with an application date of October 15.

The operational risk is not the paper itself. It is losing the original receipt date, treating an agent-collected form as unsolicited, or allowing a paper request to remain outside the team's normal inventory and deadline controls.

2. The Definition of a Lawfully Present Individual Is Changing

CMS revised the definition of “lawfully present individual” to reflect Section 1899C of the Act, which limits Medicare coverage to U.S. citizens or nationals and specified categories of eligible noncitizens: lawfully admitted permanent residents, Cuban and Haitian entrants, and Compact of Free Association residents. CMS has stated that additional guidance will be provided.

The verification mechanics matter more than the definition itself, and they leave the plan with a narrow role:

• CMS uses its systems of records, which include data from SSA systems, as the primary resource for determining lawful presence. CMS notifies the plan when an individual is not eligible to enroll on this basis, and the plan must deny the enrollment request when it has received such a notice.
• The plan may not request documentation of U.S. citizenship or lawful presence status.
• If an individual provides evidence of lawful presence to the plan, the plan may not consider it when determining eligibility for enrollment. Where there is a dispute over the individual's status, the plan should refer the person to SSA to have the status reviewed and adjusted.
• If CMS systems show that lawful presence will begin on or before the enrollment effective date, the plan must accept and process the enrollment request, even if the individual is not lawfully present when the plan receives the request.

Enrollment teams should confirm that denial workflows, analyst scripts and member-services talking points respect these boundaries, and should watch for the additional guidance CMS has promised.

3. Election-Period Logic Should Be Tested, Not Merely Documented

CMS made clarifying edits to the Initial Coverage Election Period, or ICEP, and corrected an error in a Part D Initial Enrollment Period timeline example.

The updated guidance explains how the ICEP and the Part D IEP occur together as one period when an individual enrolls in Medicare Parts A and B at first eligibility, and how the periods separate when an individual delays Part B enrollment.

CMS additionally updated guidance for certain Special Election Periods, including SEPs that require prior CMS approval, reflecting codifications in CMS-4212-F, and corrected the eligibility window for individuals whose plan or contract is terminated or modified by mutual consent.

These changes can affect more than written procedures. Plans should inspect every place where election-period logic is applied:

• Enrollment-platform configuration
• Analyst decision trees
• Desktop procedures
• Training materials
• Quality-review checklists
• Vendor instructions
• Denial reasons and notices
• Exception and escalation workflows

Testing should include cases at the edges of an election period, not only uncomplicated examples. A one-month discrepancy in an effective date or an incorrect assumption about SEP availability can lead to an enrollment being improperly rejected, delayed or submitted under the wrong election type.

Plans should also distinguish between SEPs that can be applied by the plan and those that require the individual to contact 1-800-MEDICARE because CMS approval is required prior to use. Treating these categories as interchangeable creates avoidable rework and member confusion.

4. Application Dates Require Consistent Treatment Across Channels

The application date is fundamental to determining the applicable election period, effective date and processing timeliness. But it is not established identically for every enrollment channel.

Under the updated guidance:

• For most paper requests, the application date is the date the request is initially received. A faxed request is received on the date it arrives on the plan's fax machine.
• A request collected by an agent or broker is received when the agent or broker receives it.
• For an approved telephone enrollment, the application date is the date of the call.
• For a plan-sponsored electronic enrollment, the plan must capture an accurate time and date stamp when the applicant executes the electronic signature or activates the “Enroll Now” or “I Agree” step. That stamp establishes the application date and starts the processing clock.
• The Medicare Online Enrollment Center uses specific CMS timestamp rules.
• Special processes apply to employer and union group enrollments, auto-enrollment, facilitated enrollment and certain other enrollment mechanisms.

Enrollment teams should be able to trace the date submitted to CMS back to reliable evidence from the original channel. When multiple intake systems are involved, the date a request enters the enrollment platform may not be the date CMS considers it received.

A practical review should compare the date retained by each intake channel with the application date ultimately transmitted to CMS.

5. Enrollment Capacity Limits Require Strict Sequencing

The updated guidance revises the discussion of MA enrollment capacity limits.

An MA organization may establish a capacity limit through the bid process or, in limited circumstances where the health and safety of beneficiaries is at risk, request CMS approval under the applicable regulations. Once a plan reaches its CMS-approved capacity limit, it must remain closed to prospective enrollees until space becomes available through natural attrition.

The plan must continue processing valid requests received before the limit was reached, in the order they were received. Only requests received after the plan had already reached its limit may be denied for that reason. CMS also added capacity-related denial reasons to the model denial notice (MA Exhibit 7).

That makes the accuracy of receipt timestamps and chronological processing especially important. A capacity-limit decision cannot safely be based only on when an analyst opened the request or when a transaction was submitted.

Plans with capacity limits should confirm that they can reconstruct:

• When each request was received
• When the threshold was reached
• Which requests were already in inventory
• Which requests were denied after closure
• When enrollment reopened following natural attrition

6. D-SNP Eligibility Changes Require Careful Reconciliation

CMS added detail concerning deemed continued eligibility for Special Needs Plans and the handling of individuals found ineligible for D-SNP enrollment.

A SNP may provide a period of deemed continued eligibility when an enrollee loses the special-needs status required by the plan but can reasonably be expected to regain it within six months. CMS permits a period of one to six months, provided the plan applies its chosen period consistently and fully informs enrollees of the policy.

The updated guidance specifies that the period begins on the first day of the month following the month in which information about the loss becomes available to the organization and is communicated to the enrollee. This includes retroactive Medicaid terminations.

Two notice clocks sit inside this process and both are easy to miss. The plan should notify the enrollee within 10 days of learning of the loss of special needs status, giving the individual the opportunity to show they remain eligible. And the enrollee should receive notice of disenrollment a minimum of 30 days before the disenrollment takes effect, regardless of when the loss occurred.

That creates several dates enrollment teams must keep aligned:

• The date eligibility information became available
• The date the member was notified
• The beginning and end of the deeming period
• The proposed disenrollment date
• The date the disenrollment transaction was submitted

Deemed continued eligibility does not apply when an individual was enrolled in the D-SNP erroneously because the person was not eligible initially. If a plan submits an enrollment and the state identifies the individual as ineligible under state eligibility rules before the effective date, the plan must send a cancellation immediately.

These situations are a natural source of discrepancies because Medicare enrollment data, state Medicaid eligibility information and plan records may not update simultaneously. Enrollment teams need a clear way to distinguish a temporary loss of status from an enrollment that was never valid.

7. Passive Enrollment Comes with Detailed Notice and Readiness Requirements

CMS revised its passive-enrollment guidance to address continued access to integrated care.

Passive enrollment occurs when CMS automatically enrolls an individual into another plan. It is permitted only in limited circumstances, including immediate plan terminations, situations involving potential harm and certain cases in which CMS determines that passive enrollment is necessary to promote integrated and continuous care for full-benefit dual-eligible individuals.

CMS, not the plan acting independently, determines when passive enrollment is appropriate. CMS consults with the state Medicaid agency and provides instructions to the affected organizations.

For passive enrollment intended to continue integrated care, the receiving D-SNP must send two notices:

• One at least 60 calendar days before coverage begins
• A second at least 30 calendar days before coverage begins

The notices must explain the plan's costs and benefits, how to access care and how the individual can decline the enrollment or select another plan. Notice language must be approved by CMS, and the update adds new model notices for exactly this scenario (MA Exhibits 40 and 41).

CMS also evaluates the receiving plan's operational capacity. Factors may include projected enrollment volume, performance measures, recent program audits, compliance or enforcement activity and concerns identified by the state.

For enrollment operations, this means passive enrollment is not simply a transaction file. It is a coordinated event involving eligibility data, capacity planning, notices, opt-outs, effective dates, customer-service readiness and post-enrollment reconciliation.

8. Disruptive-Behavior Disenrollment Remains a Controlled Exception

CMS added detail concerning the notice of intent to request disenrollment for disruptive behavior.

A plan cannot classify conduct as disruptive merely because an individual frequently calls the plan, refuses treatment or behaves in a way attributable to a medical or mental health condition for which the person is receiving services.

Before asking CMS for permission to disenroll an individual, the plan must make a serious effort to resolve the problems. The process then runs through two distinct notices, and both matter to the case file:

• An advance notice, which informs the individual of the adverse impact of their behavior and gives them the opportunity to stop the behavior and remain enrolled. If the behavior ceases after the advance notice and later resumes, the plan must begin the process again.
• A notice of intent, sent if the behavior continues, which tells the individual the plan intends to request CMS approval to disenroll them and explains their right to use the grievance process and to submit information or an explanation.

Dated copies of both notices must be included in the documentation submitted to CMS. The plan bears the burden of providing the information needed to support the request, and the plan cannot complete the involuntary disenrollment without CMS approval.

Although these cases may be uncommon, they require careful case management. Enrollment, member services, clinical staff, legal and compliance teams may all contribute information. The final record should show the conduct at issue, efforts to resolve it, communications with the individual, grievance activity and CMS's decision.

A Practical CY 2027 Readiness Checklist

Enrollment leaders can use the following questions to organize their implementation review.

Guidance and procedures

• Has the organization confirmed when it will begin applying the revised guidance to AEP requests?
• Has each CMS change been assigned to an operational owner?
• Have affected procedures, job aids and decision trees been identified?
• Are clarifications being distinguished from genuinely new requirements?
• Is there a process for monitoring additional CMS guidance, including the promised follow-up on the lawfully present definition?

Systems and configuration

• Have ICEP and SEP rules been tested with representative scenarios?
• Are application dates calculated correctly for every intake channel?
• Can the organization identify and work incomplete requests within required timeframes?
• Can D-SNP eligibility differences be identified before and after an effective date?
• Are cancellation, rejection and disenrollment transactions handled distinctly?

Intake and inventory

• Are downloadable paper forms available on the plan website?
• Are mail, fax, agent and electronic requests brought into a common inventory?
• Is the original date of receipt preserved?
• Can leadership see unprocessed requests, aging and approaching deadlines?

Notices and member communications

• Have the revised CY 2027 model enrollment materials and applicable notices been reviewed and incorporated into operations where relevant, including the model enrollment form (expiration date updated to February 28, 2029), MA Exhibits 7, 24, 32, 33 and 39, and new Exhibits 40 and 41?
• Have notice triggers and mailing timeframes been tested?
• Are accessible and alternate formats available when requested?
• Can the plan reproduce which version of a notice was sent and when?

Quality control

• Has the plan created test cases for unusual and borderline scenarios?
• Are denials and cancellations subject to appropriate review?
• Can recurring errors be categorized by root cause?
• Are delegated entities following the same rules and documenting the same evidence?

The Operational Takeaway

The August 2026 update is a reminder that enrollment compliance is built through daily operations.

A policy may describe the correct election period, but the result still depends on the intake channel preserving the correct date. A D-SNP may have an appropriate deemed-eligibility policy, but the member outcome still depends on timely eligibility information and notices. A plan may accept paper applications, but those requests still need to enter a controlled inventory.

For CY 2027, enrollment teams should focus on the connections between guidance, systems and case-level execution. The goal is not merely to show that the organization reviewed the CMS update. It is to ensure that each enrollment request can move from receipt to final disposition accurately, consistently and with a record that explains what happened.

Frequently Asked Questions

Primary Sources

• CMS: Medicare Advantage and Part D Enrollment and Disenrollment Guidance, updated August 25, 2026
• CMS: August 25, 2026 HPMS memorandum
• CMS: CY 2027 MA appendices and exhibits
• CMS: Medicare Managed Care Eligibility and Enrollment
• CMS: Part D Eligibility and Enrollment