After AEP closes on December 7, new Medicare clients mainly come from people turning 65, Special Enrollment Periods after life events, and your own book and the referrals who call you. The January to March Open Enrollment Period is not a sales campaign: CMS restricts marketing that targets it, so help members only when they ask.
Where do Medicare clients come from after AEP?
Medicare selling does not stop on December 7; it shifts to people whose situation gives them a way to enroll. Every month, people reach the 7-month Initial Enrollment Period around their 65th birthday and choose coverage for the first time. All year, Special Enrollment Periods open after events such as a move, the end of employer coverage or a change in Medicaid or Extra Help, under 42 CFR 422.62(b). People who join Medicare Advantage when first eligible can also change once in their first 3 months. From January 1 to March 31, people already in a Medicare Advantage plan can make one change under 42 CFR 422.62(a)(3), but CMS limits marketing aimed at that period, so treat it as a window to serve members who ask, not one to target. Because each caller's right to enroll depends on their situation, every call starts with one question: which election period, if any, does this person have right now?
| Source | When | Who qualifies | What they can do |
|---|---|---|---|
| Initial Enrollment Period | 7 months, starting 3 months before the month a person turns 65 | People new to Medicare | Join Medicare Advantage (with Parts A and B) or a drug plan |
| Special Enrollment Periods | All year, after a qualifying event | Depends on the event | Depends on the SEP; see the SEP guide for agents |
| New Medicare Advantage members | First 3 months of entitlement to Parts A and B | People who joined Medicare Advantage when first eligible | Change once: another Medicare Advantage plan or Original Medicare |
| Medicare Advantage Open Enrollment Period | January 1 to March 31 | People already in a Medicare Advantage plan | One change, on the member's initiative; marketing that targets this period is restricted |
| General Enrollment Period | January 1 to March 31 | People who did not sign up for Part B when first eligible | Sign up for Part B; some then get 2 months to join a plan |
How do turning-65 clients fit in?
People turning 65 are the steadiest post-AEP source because birthdays happen every month, and CMS's OEP marketing rule expressly allows marketing to people aging in who have not yet made an enrollment decision. Medicare.gov says the Initial Enrollment Period lasts 7 months, starting 3 months before the month a person turns 65, and joining Medicare Advantage requires both Part A and Part B. The T65 glossary entry covers the term.
Worked example: a caller whose 65th birthday is June 18, 2027 has an Initial Enrollment Period from March 1 through September 30, 2027. That is three months before June (March, April and May), June itself, and three months after (July, August and September), or 7 months in all. If she joins a Medicare Advantage plan and her Parts A and B start June 1, she can change once through August 31, the last day of her third month of entitlement. Because she joined around her 65th birthday, 42 CFR 422.62(c) also lets her return to Original Medicare any time in the 12 months after her plan starts.
What are the marketing limits during the Open Enrollment Period?
The Open Enrollment Period is for members, not for prospecting. Under 42 CFR 422.2263(b)(7), Medicare Advantage organizations may not knowingly target or send unsolicited marketing materials to Medicare Advantage enrollees during it, and plans apply that rule to the agents and brokers who sell for them. During the period, plans may not:
- Send unsolicited materials advertising the chance to make another enrollment change, or referencing the OEP.
- Specifically target people who made a choice during AEP, for example by buying mailing lists.
- Engage in or promote agent or broker activities that intend to target the OEP as an opportunity to make further sales.
- Call or otherwise contact former enrollees who selected a new plan during AEP.
The same paragraph lists what stays allowed: marketing that focuses on other enrollment opportunities, such as people aging in, 5-star plan SEPs and dual-eligible and Extra Help beneficiaries; sending materials when a beneficiary makes a proactive request; one-on-one meetings with an agent at the beneficiary's request; and information about the OEP through a call center at the beneficiary's request.
So if a Medicare Advantage member calls you between January 1 and March 31 and asks about changing plans, you can help. Confirm they are enrolled in Medicare Advantage, ask whether they already changed plans since January 1 (the period allows one election), and explain that a request the plan receives in February generally takes effect March 1. What you should not do is build ads, mail or outreach around the period.
Why does retention matter in the first 3 months?
Because early changes cost the writing agent. Under 42 CFR 422.2274(d)(5), when a member makes a plan change within the first 3 months of enrollment, the plan generally must recover the full compensation it paid for that enrollment. The rule lists exceptions, such as a move out of the service area or an enrollment effective October 1, November 1 or December 1 that changes during AEP, but a January 1 enrollment that switches in February is usually a rapid disenrollment. That is a reason to serve your own AEP clients well in January, and to help a member who asks to change only when the change truly fits their needs.
How do you build a year-round pipeline without cold calling?
Build it on contact the beneficiary starts or agrees to. Under 42 CFR 422.2264(a), Medicare Advantage marketing may not use unsolicited telephone calls, robocalls, texts or voicemails, including calls based on referrals. A call is not unsolicited when the beneficiary initiates it or consents, such as returning a call or asking to be contacted on a reply card.
- Your own book. Reviews and service give clients a reason to call you, not someone else, when their situation changes.
- Referrals who call you. You can ask clients to pass along your number; you cannot cold call the people they name.
- Inbound calls you buy. The consumer starts the call, but ask any vendor how its traffic is generated, what callers were told before they reached you, and whether any January to March advertising references the OEP.
- Educational events, run under the event rules in the same section of the regulation.
For the wider tradeoff, see inbound calls vs cold calling and TCPA basics.
How do you budget inbound calls outside AEP?
Budget by the hours you can staff first, then by price. January through March 2027 has 64 weekdays (21 in January, 20 in February and 23 in March). An agent who takes calls 3 hours each weekday has 192 hours of availability in the quarter (64 times 3), before holidays.
On Callmart, Medicare Advantage retail prices are $25 for 20 seconds, $35 for 30 seconds, $55 for 90 seconds as of November 2, 2026, and bulk buyers can request lower wholesale rates. Each tier is a buffer: a call costs its tier price only when connected time reaches that buffer. Optional campaign hours let you set one Eastern-time window per weekday, so the campaign takes calls only in the 3 hours you staff, and the receiving switch covers days you cannot work. Buy for the callers you can serve, people aging in and SEP callers, not to capture OEP switching, and track cost per enrollment by month rather than assuming AEP results carry over. The Medicare call cost guide and the cost per acquisition calculator help with the math.
What mistakes cost agents clients after AEP?
- Treating the Open Enrollment Period as a sales campaign. It only covers Medicare Advantage members, and outreach that targets it is restricted.
- Moving a brand-new member for a small difference, which can trigger a rapid disenrollment recovery for the writing agent and confuse the client.
- Asking clients for names and numbers to call, which the unsolicited contact rule prohibits.
- Missing turning-65 dates already in your book, such as a client's spouse who ages in later.
- Buying calls for hours nobody is staffed because the desk is still set up for AEP.
What belongs on a post-AEP checklist?
- Know which callers have an Initial Enrollment Period, an SEP or, for Medicare Advantage members who ask, the Open Enrollment Period.
- Keep ads, mail and outreach free of anything that targets the Open Enrollment Period.
- Keep the SEP guide at every desk.
- Track turning-65 dates in your book and among the people who call you.
- Keep recording, scope of appointment and TPMO disclaimer steps the same as in AEP.
- Set campaign hours to the hours you actually staff, and review cost per enrollment every month.
Common questions
01What is the difference between AEP and OEP?
AEP runs October 15 to December 7 and is open to everyone with Medicare, who can join, switch or drop Medicare Advantage and drug plans. The Medicare Advantage Open Enrollment Period runs January 1 to March 31, only covers people already in Medicare Advantage, allows one change, and comes with limits on marketing that targets it.
02Can agents market the Medicare Advantage Open Enrollment Period?
Not as a sales opportunity. Under 42 CFR 422.2263(b)(7), plans may not send unsolicited materials referencing the OEP or promote agent activities that target it for further sales. You can answer a member who calls you, send materials they request and meet one on one at their request.
03Can I enroll someone new in Medicare Advantage during OEP?
Not through the Open Enrollment Period itself, because it only applies to people already enrolled in Medicare Advantage. A person in Original Medicare needs another election period, such as their Initial Enrollment Period or an SEP, to join Medicare Advantage before the next AEP.
04What is the General Enrollment Period?
It runs January 1 to March 31 for people who did not sign up for Part B when first eligible, and Part B starts the month after they sign up. Medicare.gov says people without premium-free Part A who sign up then can join a drug plan, or a Medicare Advantage plan with drug coverage if they have Parts A and B, within the first 2 months.