A Medicare agency's plan from October 1 to December 7

September is the last calm month a Medicare agency gets until the new year. Medicare Advantage organizations may begin marketing next year’s plans on October 1, the Annual Enrollment Period opens on October 15 and closes on December 7, and for an agency that sells mostly Medicare, those ten weeks usually decide the year. Whatever is not built by the end of this month gets built during the rush, which usually means it does not get built.

Here is how we would spend the next four weeks, and then the ten after them.

September: get the rules into the templates

CMS’s marketing rules are not hard to follow once they live in your tools. They are very hard to follow from memory on a busy afternoon in November. So this month is for wiring them in.

• The TPMO disclaimer. If you sell for more than one organization, 42 CFR 422.2267 requires the statement that you do not offer every plan in the area, with the number of organizations and plans you represent and a pointer to Medicare.gov or 1-800-MEDICARE. It goes on the website, in email and chat, in print and TV pieces, and is spoken on every sales call before benefits come up. Update the numbers for next year’s contracts and put the statement into your email footer, chat greeting and call script now.
• Call recording. Every marketing and sales call, including web-based calls, must be recorded in full and kept for at least six years. Check that the phone system records every line your agents use, mobiles included, and that storage covers six years.
• Scope of Appointment. It must be agreed and recorded before the sales conversation, and it is valid for 12 months from the signature or from the beneficiary’s first request. Make it a step in the booking flow rather than a form someone has to remember.
• Star Ratings. If an ad mentions a plan’s Star Rating, it has to refer to the overall rating and name the contract year.

September is also the right month for educational content: what changes at 65, how the enrollment periods work, what to bring to an appointment. It is not the month for next year’s plan details. Those wait for October 1.

The outreach you can and cannot do

Most of the trouble Medicare agencies get into starts with outreach. 42 CFR 422.2264 is specific about it.

Not allowed without the beneficiary’s consent or first contact:

• Cold calls, robocalls, text messages and voicemails, including calls based on referrals.
• Direct messages on social media platforms.
• Door-to-door visits, and approaching people in common areas such as parking lots.

Allowed:

• Conventional mail and other print.
• Email, provided every message contains an opt-out.
• Calling your own clients who hold other products with you, such as auto or home insurance.
• Taking calls and booking appointments from people who reach out to you.

That shapes the whole campaign. The demand has to come to you, from search, mail, email, your existing book and referrals. On referrals, note the cap in 42 CFR 422.2274: a payment for a referral may not exceed $100 into a Medicare Advantage plan or $25 into a stand-alone drug plan.

The search and social plan for October

Search does the heaviest lifting in this window, because the beneficiary or a caregiver is the one typing. Build campaigns for the searches people make, such as a Medicare agent near them or help comparing plans, and send each to a page that carries the disclaimer and a booking path with Scope of Appointment built in. WordStream by LocaliQ’s 2026 benchmarks put the median Finance & Insurance search conversion rate at 2.64%, from April 2025 to March 2026, against 8.18% across all industries, which is why the landing page and the phone matter as much as the ad.

On Facebook and Instagram, insurance ads must run in Meta’s financial products and services special ad category, which removes age, gender and ZIP targeting. You cannot aim at people turning 65. You can write ads that people new to Medicare recognize themselves in, and let them choose to click.

Your Google profile will get more traffic in these ten weeks than in any other part of the year. BrightLocal’s 2026 consumer survey found 74% of people only care about reviews written in the last three months, so ask this year’s January enrollees for a review now, before October, while they still remember the help they got.

Staffing the ten weeks

An agency can do everything above correctly and still lose the season on the phone. A beneficiary who calls in late October and gets voicemail is likely to call the next agency on the list. Plan coverage for the hours people actually call, including early evenings, and decide now what happens to a call nobody can take: a callback within the hour, a booking link by text only when the caller asked for one, or a second line.

Two other calendars run alongside. Turning-65 enrollment never stops, because the Initial Enrollment Period lasts seven months, starting three months before the 65th birthday, so keep that page and mail sequence running through the rush. If you also sell Marketplace plans, that open enrollment overlaps the back half of this window; check HealthCare.gov for next year’s dates and your state’s own exchange if it runs one. And for agencies on the Gulf or Atlantic coast, NOAA puts the peak of hurricane season on September 10, with most activity from mid-August to mid-October, so leave room in September for home and flood questions.

After December 7, the Medicare Advantage Open Enrollment Period runs January 1 to March 31 for people already in an Advantage plan. That is a smaller window and a good time to collect reviews and referrals from the people you enrolled this fall.

What to do this month

1. Update the TPMO disclaimer with next year’s organization and plan counts, and place it in the site, chat, email footer and call script.
2. Test recording on every phone line agents use, and confirm six years of storage.
3. Build Scope of Appointment into your booking flow so no appointment exists without one.
4. Hold next-year plan ads until October 1; publish educational pages and mail pieces in September instead.
5. Ask this year’s enrollees for reviews before October.
6. Set the phone coverage plan for October 15 to December 7, including evenings and overflow.

The full picture for agencies, from P&C lines to Medicare, is on our insurance agency page. For the October search campaigns, this is how we set up Google Ads with tracking from the first click to the recorded call.