OEP vs AEP vs SEP: When Can You Sell Medicare? The Complete Guide
Understanding Medicare enrollment periods isn't just about knowing dates—it's about understanding what you can sell, how you can market, and what rules apply during each window. Getting this wrong doesn't just cost you commissions—it can cost you your carrier appointments, your license, and your livelihood. This guide breaks down every enrollment period, the specific CMS rules that govern each one, and practical sales strategies for maximizing revenue year-round.
Annual Enrollment Period (AEP): October 15 – December 7
The Annual Enrollment Period is the Super Bowl of Medicare sales. During this 54-day window, any Medicare beneficiary can make changes to their coverage for the following calendar year. They can switch from Original Medicare to a Medicare Advantage plan, change from one MA plan to another, switch from MA back to Original Medicare and add a Part D plan, join a Part D plan, switch Part D plans, or drop Part D coverage entirely. Coverage changes made during AEP take effect on January 1 of the following year.
What agents can do during AEP:
- Conduct educational events and sales presentations (with proper SOA)
- Send marketing materials to beneficiaries (following CMS-approved content guidelines)
- Make outbound calls to beneficiaries who have provided documented Permission to Contact
- Enroll beneficiaries in MA and Part D plans effective January 1
- Compare plans across carriers (if appointed with multiple carriers)
What agents cannot do during AEP:
- Cold call Medicare beneficiaries without Permission to Contact
- Conduct door-to-door sales without a prior appointment and SOA
- Discuss products not listed on the Scope of Appointment
- Use high-pressure sales tactics or create urgency beyond the actual deadline
- Offer gifts, meals, or incentives that exceed $15 in nominal value at educational events ($75 at marketing events, though rules updated in recent guidance—always check current CMS limits)
- Imply that plans are endorsed by Medicare or the federal government
AEP Scope of Appointment Rules
During AEP, a signed Scope of Appointment must be obtained at least 48 hours before any sales appointment. The SOA must list the specific product types (MA, Part D, Medicare Supplement) that will be discussed. If the beneficiary brings up a product not on the SOA during the appointment, you must decline to discuss it and schedule a separate appointment with a new SOA. Electronic SOAs are acceptable but must be documented and stored for 10 years.
AEP sales strategy: AEP is a volume game. Preparation is everything. Begin your AEP preparation at least 8 weeks before October 15. Secure your lead pipeline, stress-test your dialer, train seasonal agents, and load current-year plan data into your comparison tools. During AEP, prioritize speed-to-lead and maximize agent talk time with a Medicare-specific dialer that automates compliance workflows.
Open Enrollment Period (OEP): January 1 – March 31
The Medicare Advantage Open Enrollment Period (MA OEP) allows beneficiaries who are currently enrolled in a Medicare Advantage plan to make one change during this window. They can switch to a different Medicare Advantage plan, or disenroll from their MA plan and return to Original Medicare (and add a standalone Part D plan). Critically, this period does not allow someone on Original Medicare to enroll in an MA plan—it's only for people already in MA.
Coverage changes during OEP take effect the first of the month following the plan's receipt of the enrollment request.
What agents can do during OEP:
- Help existing MA enrollees switch to a different MA plan
- Help MA enrollees disenroll and return to Original Medicare with Part D
- Make outbound calls to current MA enrollees who have given PTC
- Respond to inbound inquiries from beneficiaries
What agents cannot do during OEP:
- Send unsolicited marketing materials specifically about OEP to beneficiaries
- Use the OEP as a selling point in outbound marketing campaigns
- Conduct OEP-specific sales events
- Enroll someone in MA who is currently on Original Medicare (they need a SEP or must wait for AEP)
- Proactively target beneficiaries to encourage them to switch plans during OEP
OEP Marketing Restrictions Are Strict
CMS significantly limits how agents can market during OEP. You cannot run campaigns that specifically reference OEP as a reason to switch plans. However, you can respond to inbound inquiries from beneficiaries who are aware of OEP and contact you for help. The key distinction is agent-initiated vs. beneficiary-initiated contact. Many agencies use this window for educational content marketing that attracts inbound inquiries without directly referencing OEP.
OEP sales strategy: Because direct OEP marketing is restricted, the best OEP strategy is retention and inbound readiness. Contact your existing book of business before January 1 (during AEP or post-AEP) to reinforce satisfaction and address concerns. This prevents competitors from poaching your clients during OEP. For new business, invest in SEO and educational content that positions you as the go-to resource when beneficiaries search for help on their own during this period.
Special Enrollment Periods (SEP): Year-Round Opportunities
Special Enrollment Periods are triggered by specific qualifying life events and allow beneficiaries to make plan changes outside of AEP and OEP. SEPs are the key to generating year-round Medicare revenue, and agents who understand them well have a significant competitive advantage.
Common SEP qualifying events include:
- Moving out of your plan's service area: Beneficiaries who move to a new address outside their current plan's service area qualify for a SEP to choose a new plan. This is one of the most common SEPs and applies to MA, Part D, and Medigap.
- Losing employer or union coverage: When a beneficiary loses group health coverage (through retirement, job loss, or employer dropping coverage), they qualify for a SEP to enroll in Medicare coverage.
- Dual-eligible status changes: Beneficiaries who gain or lose Medicaid eligibility, or who qualify for the Low-Income Subsidy (LIS/Extra Help), receive a SEP that can be used once per quarter.
- Plan contract violations: If a plan violates its contract terms (for example, failing to provide medically necessary services), affected beneficiaries receive a SEP.
- Institutionalization: Beneficiaries who move into or out of a skilled nursing facility qualify for a SEP.
- Natural disasters: FEMA-declared disaster areas may trigger SEPs for affected beneficiaries.
- Incarceration release: Individuals released from incarceration qualify for a SEP to enroll in Medicare coverage.
5-Star SEP: One particularly valuable SEP is the 5-Star Special Enrollment Period, available from December 8 through November 30 of the following year. Beneficiaries can use this SEP once per year to switch to a Medicare Advantage or Part D plan that has received a 5-star rating from CMS. If you're contracted with a 5-star plan, this gives you an 11.5-month sales window outside of AEP.
Document SEP Eligibility Thoroughly
SEP enrollments are frequently audited. For every SEP enrollment, document the qualifying event, the date it occurred, supporting evidence (such as a change-of-address confirmation or employer termination letter), and the beneficiary's attestation. Carriers may retroactively disenroll beneficiaries who can't demonstrate a valid qualifying event—and the commission clawback comes out of your pocket.
Initial Enrollment Period (IEP): Around the 65th Birthday
The Initial Enrollment Period is a 7-month window surrounding a person's 65th birthday during which they can first enroll in Medicare. It starts 3 months before the month they turn 65, includes the birthday month, and extends 3 months after. For example, if someone turns 65 in June, their IEP runs from March 1 through September 30.
During the IEP, eligible individuals can sign up for Medicare Part A, Part B, Medicare Advantage, Part D, and Medicare Supplement plans. This is the most comprehensive enrollment window and the point at which most Americans first enter the Medicare system.
IEP sales strategy: The IEP is extremely valuable because these are first-time Medicare enrollees who are often confused, overwhelmed, and actively seeking guidance. They have no existing plan loyalty and are making decisions that will affect their healthcare for years. Marketing to turning-65 prospects is one of the most effective year-round strategies. Direct mail, digital advertising targeting age 64-65 demographics, and community seminars all perform well for IEP prospects. The key is reaching them 2-3 months before their 65th birthday—before a competitor does.
Initial Coverage Election Period (ICEP)
The ICEP is closely related to the IEP but applies specifically to Medicare Advantage and Part D enrollment. It's the 3-month period that begins when a person first becomes entitled to both Medicare Part A and Part B. For most people turning 65, the ICEP overlaps with their IEP. However, for people who delay Part B enrollment (because they have employer coverage, for example), the ICEP doesn't begin until they actually enroll in Part B.
Understanding the distinction between IEP and ICEP matters because it affects when a beneficiary can enroll in MA plans specifically. If someone signs up for Part A at 65 but delays Part B until 67 (when they retire), their ICEP for MA doesn't begin until Part B coverage starts.
CMS Marketing Rules: What Applies During Each Period
CMS marketing rules are not one-size-fits-all—they vary by enrollment period. Understanding these distinctions is critical to staying compliant:
- AEP (Oct 15 – Dec 7): Most marketing activities are permitted with proper documentation. SOA required 48 hours in advance of sales appointments. All marketing materials must be CMS-approved or follow CMS model content guidelines. Outbound calls require PTC.
- OEP (Jan 1 – Mar 31): Severely restricted. No outbound marketing referencing OEP. No sales events promoting OEP. Agent-initiated contact about OEP is prohibited. Beneficiary-initiated contact is permitted.
- SEP (Year-round): Marketing to SEP-eligible individuals is permitted but must be truthful and not misleading. You cannot encourage someone to create a qualifying event to gain SEP eligibility. All standard marketing rules apply.
- IEP (Year-round, per individual): Marketing to turning-65 individuals is permitted year-round. All standard marketing rules apply. Educational seminars targeting this audience are common and effective.
Building a Year-Round Medicare Sales Strategy
The most successful Medicare agencies don't shut down between enrollment periods—they adjust their strategy to capitalize on every available window:
- January – March (OEP): Focus on retention of existing clients, respond to inbound OEP inquiries, ramp up turning-65 marketing, and pursue SEP opportunities with dual-eligible beneficiaries.
- April – June: Heavy focus on turning-65 IEP prospects, SEP opportunities (movers, job changers, dual-eligible), cross-selling ancillary products (dental, vision, final expense), and begin AEP preparation.
- July – September: AEP preparation intensifies—hire and train seasonal agents, test technology, secure lead contracts, load plan data, and build marketing campaigns. Continue IEP and SEP sales.
- October – December (AEP): All hands on deck for AEP. Maximize lead volume, extend hours, and prioritize speed and compliance. Continue IEP enrollments for beneficiaries turning 65 during this period.
Compliance Technology Makes Year-Round Sales Manageable
Managing different marketing rules across multiple enrollment periods is complex. A Medicare-specific dialer can automatically enforce period-specific compliance rules—blocking certain outbound campaigns during OEP, requiring SOA documentation during AEP, and verifying SEP eligibility before processing enrollments.
Sell Medicare Compliantly in Every Enrollment Period
AgentTech Dialer has built-in compliance guardrails for AEP, OEP, SEP, and IEP—so your agents stay compliant no matter what time of year they're selling. Automated SOA workflows, real-time compliance monitoring, and period-specific marketing controls keep your agency safe.
Try AgentTech Dialer NowReferences & Authoritative Sources
The information on this page is supported by the following official and authoritative sources.
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Medicare.gov Medicare.gov
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