Best Practices March 5, 2026

SEP Opportunities: How Special Enrollment Periods Create Year-Round Revenue

AgentTech Team

Insurance Industry Specialists

Most Medicare agencies generate the vast majority of their revenue during the 54-day Annual Enrollment Period—and then scramble to keep the lights on for the other 10 months. But Special Enrollment Periods create legitimate, compliant opportunities to enroll beneficiaries in Medicare Advantage plans year-round. Agencies that master SEP identification, marketing, and conversion build sustainable revenue streams that eliminate the feast-or-famine cycle entirely.

What You'll Learn

Every type of SEP qualifying event and how to identify eligible beneficiaries
Targeted marketing strategies for each SEP type
Compliance guardrails that keep your agency audit-proof
Call center operational workflows for SEP sales
A year-round revenue model that eliminates seasonal dependency

What Are Special Enrollment Periods?

A Special Enrollment Period is a window outside of the standard Annual Enrollment Period (October 15 – December 7) and the Medicare Advantage Open Enrollment Period (January 1 – March 31) during which a Medicare beneficiary can enroll in, switch, or drop a Medicare Advantage or Part D plan. SEPs are triggered by specific qualifying life events defined by CMS, and each event type carries its own eligibility window, documentation requirements, and marketing rules.

Unlike AEP, where every Medicare beneficiary is eligible to make changes, SEPs are available only to individuals who experience a qualifying event. This makes SEP marketing more targeted—and, when done correctly, more efficient. You're reaching people who have a genuine, immediate need for coverage changes rather than casting a wide net during a compressed enrollment window.

Why SEPs Matter for Agency Revenue

CMS data shows that SEP enrollments account for a growing share of total Medicare Advantage enrollments each year (see Star Ratings for plan quality). Agencies that build dedicated SEP programs report a significant portion of their annual revenue coming from outside of AEP, often estimated at 25–40% by industry analysts. That's the difference between a seasonal operation and a sustainable business. If you're only selling during AEP, you're leaving nearly half your potential revenue on the table.

Types of Qualifying Events That Trigger SEPs

Understanding each SEP type is the foundation of a year-round sales strategy. Each qualifying event creates a different prospect profile, requires different documentation, and responds to different marketing approaches. Here are the major SEP categories every Medicare agency should be working:

1. Change of Residence (Moving SEP)

When a beneficiary permanently moves out of their current plan's service area, they qualify for a SEP to select a new Medicare Advantage or Part D plan available in their new location. This is one of the most common and highest-volume SEP types, particularly in states with significant retiree migration like Florida, Arizona, Texas, and the Carolinas.

Moving SEP Details

Eligibility Window: Beneficiary can make changes up to 2 months before their move date and up to 2 months after the move
Documentation Required: Change-of-address confirmation, utility setup, lease agreement, or other proof of new permanent residence
Coverage Effective Date: First of the month following enrollment request receipt
Key Nuance: The move must be permanent—snowbirds who maintain their primary residence don't qualify unless they change their official address

2. Loss of Creditable Coverage

Beneficiaries who involuntarily lose their current health coverage—through employer plan termination, retirement, job loss, divorce, or aging off a parent's plan—qualify for a SEP. This is especially significant during periods of corporate layoffs or when employers discontinue retiree health benefits, which is happening with increasing frequency.

Loss of Coverage SEP Details

Eligibility Window: Up to 2 months before and 2 months after the date coverage ends
Documentation Required: Employer termination letter, COBRA notice, or creditable coverage end date documentation
Coverage Effective Date: Can be retroactive to the first of the month the previous coverage ended
Key Nuance: The loss must be involuntary. Voluntarily dropping employer coverage to enroll in MA does not qualify

3. Dual-Eligible SEP (Medicare-Medicaid)

Beneficiaries who are dually eligible for both Medicare and Medicaid receive one of the most powerful SEPs available—they can switch Medicare Advantage plans or enroll in a new plan once per calendar quarter (January–March, April–June, July–September). This means a dual-eligible beneficiary can make up to three plan changes per year outside of AEP. Additionally, beneficiaries who qualify for the Low-Income Subsidy (LIS/Extra Help) for Part D also receive a quarterly SEP.

Why Dual-Eligible Is the Highest-Value SEP

Dual-eligible beneficiaries represent one of the largest and most underserved populations in Medicare. There are approximately 12 million dual-eligible individuals nationwide, and many are enrolled in suboptimal plans or have never been presented with Dual-Eligible Special Needs Plans (D-SNPs) designed specifically for their needs.

Quarterly enrollment windows (3 opportunities per year outside AEP)
D-SNP plans often carry higher commissions than standard MA plans
Less competition—many agencies don't target this segment
State Medicaid agencies can provide eligibility verification data

4. Institutional SEP (SNF/Long-Term Care)

Beneficiaries who move into, reside in, or move out of a skilled nursing facility (SNF), long-term care facility, or other institutional setting qualify for a monthly SEP. This means they can make a plan change every single month—the most frequent SEP available. This population is often best served by Institutional Special Needs Plans (I-SNPs) designed for their care needs.

Institutional SEP Details

Eligibility Window: Available every month while the beneficiary is in an institutional setting
Documentation Required: Facility admission or residence verification
Coverage Effective Date: First of the month following enrollment
Key Nuance: Also applies to beneficiaries leaving an institution—they qualify for a 2-month SEP after discharge

5. 5-Star Plan SEP

The 5-Star SEP is one of the most valuable and underutilized enrollment opportunities in Medicare. From December 8 through November 30 of the following year, any Medicare beneficiary can use this SEP once to switch to a Medicare Advantage or Part D plan that has earned a 5-star quality rating from CMS. That's an 11.5-month enrollment window—essentially year-round sales if you're contracted with a 5-star plan.

5-Star SEP Strategy

If you're not currently contracted with a 5-star rated plan, make it a priority. Check the CMS Medicare Plan Finder each fall when new star ratings are released (usually in October). Get appointed with every 5-star plan available in your selling states. This single step can transform your agency from an AEP-dependent operation into a year-round revenue engine. Note: CMS publishes the list of 5-star plans on Medicare.gov, and beneficiaries can also find them—so competition is growing. Move fast.

6. Other Qualifying SEP Events

FEMA-Declared Disasters

Beneficiaries in FEMA-declared disaster areas receive a SEP. Duration varies by FEMA declaration. Monitor FEMA.gov for active declarations in your selling states.

Incarceration Release

Individuals released from incarceration qualify for a SEP to enroll in Medicare coverage. Reentry organizations can be valuable referral partners for this segment.

Plan Contract Violations

When a plan violates its contract or fails to provide medically necessary services, affected beneficiaries receive a SEP. CMS publishes enforcement actions publicly.

Plan Non-Renewal

When a carrier terminates or non-renews a plan, affected enrollees get a SEP. Monitor CMS plan crosswalk files to identify these opportunities early.

How to Identify SEP-Eligible Beneficiaries

The biggest challenge with SEP sales isn't the enrollment process—it's finding eligible beneficiaries at the right time. Unlike AEP, where every Medicare beneficiary is a potential prospect, SEP eligibility is event-driven and time-limited. Here are proven strategies for identifying SEP-eligible prospects:

SEP Identification Strategies

1
Mine your existing book of business. Contact current clients regularly. Life changes—moves, job changes, Medicaid eligibility—often go unreported to agents. Quarterly check-in calls can surface SEP opportunities you'd otherwise miss.
2
Partner with community organizations. Senior centers, social workers, hospitals, SNFs, Medicaid offices, and reentry programs regularly encounter people experiencing qualifying events. Build referral relationships with these organizations.
3
Monitor public data sources. USPS address change filings, FEMA disaster declarations, employer layoff announcements (WARN Act notices), and CMS plan termination/non-renewal files all signal SEP-eligible populations.
4
Invest in inbound digital marketing. People experiencing qualifying events actively search for help online. SEO content targeting phrases like "lost my health insurance Medicare," "moving to Florida Medicare," or "Medicare after retirement" captures high-intent SEP-eligible prospects.
5
Purchase targeted SEP leads. Lead vendors increasingly offer SEP-specific leads, including recently moved seniors, newly Medicaid-eligible individuals, and T65 prospects losing employer coverage. Vet vendors carefully and track lead-to-enrollment conversion rates.

Marketing Strategies for Each SEP Type

Each SEP type requires a different marketing approach because the prospect's situation, urgency level, and information needs are fundamentally different. A one-size-fits-all campaign won't work. Here's how to tailor your marketing by SEP type:

SEP Marketing Playbook

Moving/Relocation SEP

Target: Seniors relocating to your state or service area. Channels: Google Ads for "[state] Medicare plans," welcome mailers to new movers, partnerships with real estate agents and moving companies, local community welcome programs. Message: "New to the area? Make sure your Medicare coverage moves with you."

Loss of Coverage SEP

Target: Recent retirees or individuals losing employer coverage. Channels: LinkedIn Ads targeting recently retired professionals, HR department partnerships, employer benefits fair presence, COBRA expiration outreach. Message: "Retiring or losing employer coverage? You have options."

Dual-Eligible SEP

Target: Beneficiaries with both Medicare and Medicaid. Channels: Community health center partnerships, social service agency referrals, Medicaid office relationships, targeted digital ads. Message: "You may qualify for extra benefits at no cost through a Dual Special Needs Plan."

Institutional SEP

Target: Beneficiaries entering or leaving SNFs and long-term care. Channels: Direct facility partnerships, discharge planner relationships, social worker referrals. Message: "We help ensure your Medicare plan matches your care needs—whether you're entering or leaving a care facility."

5-Star Plan SEP

Target: Any Medicare beneficiary dissatisfied with their current plan. Channels: Digital ads, direct mail, educational seminars, SEO content. Message: "Unhappy with your Medicare plan? You may be able to switch to a top-rated 5-star plan right now—no need to wait for open enrollment."

Compliance Considerations for SEP Enrollments

SEP enrollments carry unique compliance risks that differ from AEP. The most common compliance failures in SEP sales involve inadequate documentation of the qualifying event, enrolling beneficiaries who don't actually have a valid SEP, and failing to verify eligibility before submitting applications. CMS and carriers audit SEP enrollments more aggressively than AEP enrollments because of the higher potential for abuse. For a complete overview of Medicare compliance requirements, see our Medicare Compliance Guide.

Critical Compliance Requirements for SEP Sales

Document everything. For every SEP enrollment, you must collect and retain: (1) the specific qualifying event type, (2) the date the event occurred, (3) supporting evidence such as a change-of-address form, termination letter, Medicaid eligibility notice, or facility admission record, and (4) the beneficiary's signed attestation confirming the qualifying event. Carriers may retroactively disenroll beneficiaries who cannot prove their SEP eligibility—and the resulting commission clawback and potential CMS investigation come at your agency's expense.

SEP Compliance Checklist

Verify the qualifying event and its date before beginning the sales process
Collect supporting documentation (proof of move, coverage termination letter, Medicaid notice, etc.)
Obtain a signed Scope of Appointment before the sales presentation
Record all calls and maintain recordings per CMS and state requirements
Confirm the beneficiary is within the valid SEP eligibility window
Never encourage a beneficiary to create a qualifying event to gain SEP eligibility
Retain all SEP documentation for a minimum of 10 years per CMS record retention requirements

Call Center Operations During SEP

Running SEP sales through a call center requires different operational workflows than AEP. The volume is lower but the complexity per call is higher, because agents must verify eligibility, collect documentation, and navigate event-specific rules. Here's how to optimize your call center for SEP efficiency. If you haven't already, review our guide to call routing strategies for structuring your queues.

SEP Call Center Workflow

Inbound SEP Calls

IVR option for "life change or coverage change"
Route to SEP-trained agents only
Qualify the SEP type and event date immediately
Collect documentation during the call if possible

Outbound SEP Campaigns

Segment lists by SEP type for targeted messaging
Use compliance-approved SEP-specific scripts
Configure dialer for SEP contact attempt limits
Track SEP-specific conversion metrics

Agent Training

Train agents on all SEP types and eligibility windows
Role-play documentation collection scenarios
Test comprehension with AI mock calls
Certify agents for SEP sales separately from AEP

Quality Assurance

Audit 100% of SEP enrollments for documentation
Review call recordings for compliance language
Track SEP-specific disenrollment/clawback rates
Flag agents with above-average SEP rejection rates

Pro Tip: Dedicated SEP Queue

Create a dedicated SEP queue in your dialer and staff it with your most knowledgeable, compliance-conscious agents. SEP calls take longer and require more expertise than standard AEP calls, but the conversion rates are typically higher because the beneficiary has an active, immediate need. Routing SEP calls to general agents who aren't trained on eligibility verification and documentation requirements is a recipe for compliance violations and clawbacks.

Building a Year-Round Revenue Model

The most successful Medicare agencies don't treat SEPs as a side project—they build structured, year-round programs that generate predictable revenue every month. Here's how to build your year-round revenue model using SEPs alongside other enrollment periods. For AEP-specific planning, see our AEP Preparation Checklist.

Year-Round Medicare Revenue Calendar

Q1: January – March

OEP retention & inbound response
Dual-eligible quarterly SEP (Jan–Mar)
5-Star plan SEP enrollments
T65/IEP marketing ramp-up

Q2: April – June

Dual-eligible quarterly SEP (Apr–Jun)
Moving season SEP outreach
Employer retirement wave SEPs
5-Star plan enrollments continue

Q3: July – September

Dual-eligible quarterly SEP (Jul–Sep)
Peak moving season SEPs
AEP preparation begins
Seasonal agent hiring & training

Q4: October – December

AEP (Oct 15 – Dec 7) primary focus
SEP enrollments continue alongside AEP
New star ratings released—prep 5-Star
Post-AEP follow-up & retention

Revenue Impact: The Numbers

Industry analysts suggest that an agency that generates 100 enrollments during AEP and adds a structured SEP program can realistically add 30–50 additional enrollments throughout the year—a 30–50% increase in total production with significantly lower cost-per-acquisition than AEP leads. The key is treating SEP as a dedicated business line with its own budget, staff allocation, lead sources, and KPIs rather than an afterthought that only gets attention when AEP ends.

Technology Requirements for SEP Programs

A successful year-round SEP program demands technology that supports event-driven enrollment workflows, not just the batch-processing approach most agencies use during AEP. Here's what your technology stack needs:

SEP Technology Checklist

CRM with SEP tracking fields: Qualifying event type, event date, eligibility window expiration, documentation status
Dialer with SEP-specific queues: Separate call queues, scripts, and routing rules for SEP vs. AEP campaigns
Document collection system: Secure method for collecting and storing SEP eligibility documentation
Compliance monitoring: Real-time call monitoring with SEP-specific compliance rules and keyword alerts
Automated eligibility window tracking: Alerts when a prospect's SEP eligibility is about to expire
Reporting and analytics: SEP-specific KPIs including conversion rate by SEP type, documentation completion rate, and clawback rate

Build Your Year-Round Medicare Revenue Engine

AgentTech Dialer supports SEP-specific workflows out of the box: dedicated queues, compliance-approved scripts, AI-powered eligibility verification prompts, real-time compliance monitoring, and SEP performance analytics. Stop depending on AEP alone—build a sustainable, year-round Medicare business.

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