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What changed in the enrollment guidance for 2027?

What changed in the CY 2027 enrollment guidance touches on several binding regulation provisions in the excerpts — the SEP prior-approval list and the passive enrollment rules — so those must be quoted alongside the guidance summary.

This answer relies on CMS enrollment guidance for CY 2027, which applies to enrollment requests received on or after January 1, 2027 (and plans may apply it to AEP enrollments effective January 1, 2027).

What the rule says

On updates to SEPs requiring prior CMS approval, the underlying regulation lists which SEPs need approval:

“All of the following SEPs require CMS approval prior to use:”
42 CFR § 423.32(k)(2)
“SEP for individuals who were not adequately informed of a loss of creditable prescription drug coverage, § 423.38(c)(2).”
42 CFR § 423.32(k)(2)(i)

The guidance summary notes this area was updated:

“Updates to SEPs that require prior CMS approval, based on codifications in CMS- 4212-F”
CY 2027 Enrollment Guidance – Summary of Updates

On passive enrollment, which the summary says was revised for Section 40, the regulation sets the notice timing:

“The first notice described in paragraph (g)(4)(ii) of this section must be provided, in a form and manner determined by CMS, no fewer than 60 calendar days prior to the enrollment effective date.”
42 CFR § 422.60(g)(4)(ii)(A)
“The second notice described in paragraph (g)(4)(ii) of this section must be provided, in a form and manner determined by CMS, no fewer than 30 days prior to the enrollment effective date.”
42 CFR § 422.60(g)(4)(ii)(B)

The guidance summary states:

“Revised passive enrollment requirements based on continued access to integrated care”
CY 2027 Enrollment Guidance – Summary of Updates

On other Section 30 updates, general capacity, IEP, ICEP, and mutual-consent-termination edits, and on Section 60 and model exhibit changes, the excerpts contain only the guidance summary, with no corresponding regulation text quoted:

“Revised the discussion of enrollment capacity limits.”
CY 2027 Enrollment Guidance – Summary of Updates
“Corrected an error in IEP timeline example”
CY 2027 Enrollment Guidance – Summary of Updates
“Clarifying edits about the ICEP window, based on recent inquiries”
CY 2027 Enrollment Guidance – Summary of Updates
“Correction to eligibility window for the SEP for individuals whose plan or contract is terminated/modified by mutual consent”
CY 2027 Enrollment Guidance – Summary of Updates
“Added details about the required availability of paper enrollment forms under CMS marketing requirements”
CY 2027 Enrollment Guidance – Summary of Updates
“Added explanation of the start date of deemed continued eligibility”
CY 2027 Enrollment Guidance – Summary of Updates
“Added details about the notice of intent to request disenrollment for disruptive behavior”
CY 2027 Enrollment Guidance – Summary of Updates
“This release is intended to replace our existing enrollment guidance documents. This guidance is effective January 1, 2027.”
CY 2027 Enrollment Guidance – Summary of Updates

Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.

This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.

Sources cited

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