Medicare AEP Outsourcing: 2026 Buyer Guide for the October Surge

Every Medicare carrier, Medicare Advantage plan operator, FMO, and brokerage runs the same calendar. Nine months of the year you have a baseline licensed team handling member service, T-65 outreach, and the trickle of Special Enrollment Period activity. Then on October 15 the floor falls out from under your queue, and for 54 straight days you handle 8 to 10 times the call volume of any other window in the year. The teams that win AEP are the ones that locked in BPO capacity in spring and finished their AHIP, state licensing, and plan training by late September.

Today is April 27, 2026. The upcoming AEP runs October 15, 2026 through December 7, 2026 and determines 2027 coverage for every Medicare beneficiary in the country. This guide walks buyers through what to outsource, what it costs, what licensing your agents need, the pre-AEP timeline, and why most Medicare carriers have moved AEP work to nearshore Caribbean and Latin American operations rather than offshore. If you want the year-round Medicare BPO picture, our Medicare call center outsourcing pillar covers that ground separately.

When AEP Starts and Why Prep Begins Now

The 2026 Annual Enrollment Period runs October 15 to December 7, 2026, with plans taking effect January 1, 2027. Buyers contract BPO capacity in May through July because licensing, AHIP, and plan training take 4 to 6 weeks per agent before they can take live calls.

The Medicare Annual Enrollment Period is fixed in federal regulation. It opens at 12:01 AM on October 15, 2026 and closes at 11:59 PM on December 7, 2026. During those 54 days, beneficiaries can switch between Original Medicare and Medicare Advantage, change MA plans, change Part D drug plans, or enroll in or drop Part D coverage. Plans selected during AEP take effect January 1, 2027. The Medicare Advantage Open Enrollment Period (OEP) follows from January 1 through March 31, 2027, allowing one additional MA-to-MA or MA-to-Original-Medicare switch.

The reason buyers have to start planning now, in late April, is that the supporting infrastructure cannot be built in October. Annual AHIP Medicare certification typically opens in late June and most carriers require completion by August or September. State health insurance producer licenses take 2 to 6 weeks per state depending on the department. Carrier-specific and plan-specific product training runs 1 to 3 weeks. By the time you stack those requirements, an agent who is not yet certified in May cannot reliably take a live AEP call on October 15.

Contracting with a BPO in May or June gives you and your partner a runway: the BPO can recruit and pre-screen, you can review staffing plans, AHIP releases in late June, agents complete it through July and August, state licensing runs in parallel, plan-specific training happens in September, and the full surge team is on the floor by October 1, two weeks before AEP opens. Buyers who try to contract in August are routinely told that licensed Medicare seats have already sold out for the year.

What Functions Carriers Outsource During AEP

Inbound enrollment, outbound T-65 outreach, plan comparison support, billing questions, member onboarding, eligibility verification, complaint and grievance intake, and post-enrollment welcome calls are the core AEP outsourcing functions for carriers and MA plans.

Buyers do not outsource AEP as one undifferentiated workload. They outsource specific functions, often to the same partner running multiple licensed and unlicensed teams in parallel. The most common AEP outsourcing scopes:

• Inbound AEP enrollment: Licensed agents take inbound calls from prospects responding to direct mail, TV, digital, and FMO lead generation. They run the Scope of Appointment, do plan comparison, present plan benefits, and complete the enrollment application end to end.
• Outbound T-65 and aging-in outreach: Calls to beneficiaries turning 65 in the next 3 to 6 months, plus calls into existing books for plan reviews. Year-round work that intensifies in pre-AEP and AEP windows.
• Plan comparison support: Beneficiaries calling to compare two or three plans before deciding. Requires deep product knowledge and Star Ratings literacy, not just script reading.
• Billing and premium support: First-month premium questions, autopay setup, low-income subsidy (LIS) processing, billing discrepancies. Volume spikes again in January as new plans take effect.
• Member onboarding and welcome calls: Outbound welcome calls within 7 to 10 days of enrollment, ID card delivery confirmation, PCP selection assistance, mail-order pharmacy setup.
• Eligibility verification: Real-time CMS MARx checks, dual-eligible verification, LIS subsidy verification before enrollment.
• Complaint and grievance intake: CMS-tracked grievance categorization and routing, including secret shopper complaint handling that affects Star Ratings.
• Post-enrollment care navigation: Helping new members find in-network providers, transitioning prescriptions, scheduling annual wellness visits.

Most carriers split these into two BPO buckets: licensed agents for anything that touches enrollment or plan benefits, and unlicensed customer service agents for billing, ID cards, eligibility, and care navigation. The licensed bucket runs at the higher hourly rate. The unlicensed bucket runs closer to a standard healthcare call center outsourcing rate.

Licensed Agents: State Lines, AHIP, and Plan-Specific Training

AEP enrollment agents need annual AHIP Medicare certification (released late June), a resident or non-resident health insurance producer license in every state they sell into, carrier-specific and plan-specific product training, and Scope of Appointment proficiency. Most certifications must be locked in by late August.

The CMS Medicare Communications and Marketing Guidelines (MCMG) and individual carriers stack four layers of training and licensing on every AEP enrollment agent. None of them are optional, and none of them can be skipped if the agent is going to discuss plan benefits, run a Scope of Appointment, or complete an enrollment.

1. AHIP Medicare Certification

AHIP releases the new annual certification module in late June each year. Most carriers require completion before they will release plan-specific training. AHIP runs roughly 4 to 8 hours of self-paced study and a proctored exam covering Medicare basics, fraud, waste, and abuse, the MCMG, and broker compliance. Pass rates favor experienced agents; new agents often need a second attempt. Most carriers also accept NAHU or America's Health Insurance Plans equivalents.

2. State Insurance Producer Licensing

Every agent needs a resident health insurance producer license in their home state, plus non-resident licenses in every state they sell into. For nearshore agents whose home jurisdiction is outside the US, the producer license is held in a designated state of resident-equivalency, with non-resident licenses in every state of sale. State exams take 2 to 6 weeks depending on department backlog. Background checks add another 2 to 4 weeks. Plan to start state licensing in May for any new agent who is not already licensed.

3. Carrier and Plan-Specific Training

Each MA carrier runs its own product training on plan benefits, formularies, network rules, supplemental benefits, and Star Ratings positioning. Carriers also run scenario-based training on tricky enrollment patterns: dual-eligibles, LIS, chronic-condition special needs plans, and EGWP. Plan training typically runs 1 to 3 weeks per carrier, and agents commonly carry 2 to 4 carriers each.

4. Scope of Appointment (SOA) and CMS Scripting

CMS requires a documented SOA before any sales discussion of MA or Part D plans. Agents must master the SOA workflow, the CMS-approved verbal disclaimer (TPMO disclaimer), the prohibition on cross-selling outside the SOA, and the rules around recording and retaining the SOA. Secret shoppers test SOA execution, and missed disclaimers are a fast path to a CMS marketing violation.

The cumulative effect is that an agent who starts the licensing process in May can be ready by late September. An agent who starts in August will not be ready for AEP. This is the single most important reason buyers contract early.

Volume Math: Surge Multipliers and Seat Planning

Medicare carriers and MA plans typically see AEP-period call volume of 8 to 10 times the non-AEP baseline. A plan staffing 30 licensed seats year-round commonly ramps to 240 to 300 licensed seats during AEP and back down by December 8.

The volume curve is brutal and predictable. Year-round, a regional MA plan or carrier line of business might handle 2,000 to 4,000 inbound enrollment-eligible calls per week. From October 15 onward that volume jumps to 18,000 to 35,000 per week, peaks in mid-October and again in the final week before December 7, then collapses back to baseline within 3 days of close.

Sample Sizing for a 30-Seat Year-Round Plan

Take a Medicare Advantage plan that runs 30 licensed agents year-round handling member service, T-65 outreach, and SEP enrollments. A 9x AEP surge multiplier means total demand of 270 licensed seats during peak weeks. Most plans split the surge across:

• Year-round core team: 30 seats (in-house or BPO).
• Returning seasonal agents: 60 to 90 seats. Last year's AEP cohort, recertified for the new plan year. Lowest training cost, highest productivity.
• New seasonal hires: 120 to 180 seats, recruited and licensed between May and September.
• Overflow / peak-week capacity: 30 to 60 seats added for the first 10 days of AEP and the final 7 days before close. Often unlicensed customer service routing pre-screened calls back to licensed agents.

Buyers who try to ramp without the returning-cohort layer pay an extra 15 to 25 percent in licensing and training cost because every seat is a new agent. This is why the standard model is to lock in a BPO partner you can return to year over year, retaining the licensed talent across multiple AEP cycles. Our dedicated agent model is what makes this possible. Shared agent pools cannot retain Medicare-licensed staff between AEP cycles.

What It Costs in 2026

Onshore licensed AEP agents cost $35 to $50 per hour fully loaded. Nearshore Caribbean and Latin American licensed agents cost $14 to $22 per hour fully loaded. Surge premiums of 10 to 20 percent are common during peak weeks. Per-seat all-in monthly costs run $3,800 to $6,500 nearshore versus $7,500 to $11,000 onshore.

Onshore vs nearshore licensed AEP agent cost comparison 2026

Model	Hourly (Fully Loaded)	Per-Seat Monthly (AEP)	Notes
Onshore licensed (US)	$35 to $50	$7,500 to $11,000	W-2 + 1099 mix; benefits, QA, tech, and overhead loaded
Nearshore licensed (Jamaica, Trinidad, Colombia)	$14 to $22	$3,800 to $6,500	AHIP + state-licensed; English or bilingual EN/ES
Offshore licensed (PH, India)	n/a	n/a	Generally not used for Medicare due to CMS recording, PHI cross-border, and FCC NPRM disclosure overhead
Nearshore unlicensed (member services)	$10 to $16	$2,800 to $4,800	Billing, ID cards, care nav, eligibility

The hourly rate is only part of the picture. AEP carries real surge premiums: most BPOs price peak weeks (October 15 to November 5 and the final week before December 7) at 10 to 20 percent above base hourly. Overtime pay during the final 72 hours can run to 50 percent above base. Buyers planning a tight budget tend to under-staff base capacity and over-rely on overtime, which is the most expensive way to staff the curve. The lower-cost path is contracting more base seats earlier and running lighter overtime at peak. For more on what gets bundled into a fully loaded hourly rate, see our 2026 nearshore outsourcing cost breakdown.

Compliance: CMS, HIPAA, and Recording Rules

CMS requires Medicare marketing and sales calls to be recorded and retained for 10 years. The TPMO disclaimer is mandatory. Scope of Appointment must be documented before any plan discussion. Off-script promises are prohibited. Carriers and CMS run secret shopper monitoring throughout AEP.

Medicare AEP outsourcing carries a heavier compliance footprint than almost any other BPO workload. The non-negotiables:

• 10-year call recording retention. CMS requires recording and retention of all marketing and sales calls related to MA and Part D plans for 10 years. Your BPO must operate a recording infrastructure that meets this retention requirement, with searchable retrieval for CMS audits.
• TPMO disclaimer. Third-Party Marketing Organizations must read the CMS-approved disclaimer at the start of every Medicare-related sales call. Wording is fixed and cannot be paraphrased.
• Scope of Appointment. Documented SOA before any discussion of plan benefits. SOA must specify the products to be discussed and is retained alongside the recording.
• No off-script promises. Agents cannot promise outcomes (savings, network access, formulary coverage) outside the documented plan materials. CMS treats unscripted claims as marketing violations.
• Secret shopper monitoring. CMS, carriers, and FMOs run secret shopper calls during AEP. Failure rates feed Star Ratings and CMS sanctions.
• HIPAA and PHI handling. Standard HIPAA call center requirements apply on top of CMS rules: BAA, encrypted transmission, restricted access, audit logging.

Compliance is not just a cost center for AEP outsourcing, it is a Star Ratings input. Plans with high marketing-violation rates lose Star Ratings points, which compound into lower CMS quality bonus payments the following plan year. The compliance discipline of your BPO partner directly affects your 2028 plan year revenue.

Bilingual Coverage: Why Hispanic Enrollees Matter

There are more than 5 million Hispanic Medicare beneficiaries, and Hispanic Medicare Advantage enrollment is growing roughly 4x faster than overall MA enrollment. Spanish-language member experience is also a Star Ratings factor, which is why bilingual nearshore Colombian and Caribbean operations are increasingly the default for AEP.

The Hispanic Medicare market is the fastest-growing segment in MA, both in raw enrollment and in switching activity during AEP. Carriers without strong native Spanish-language enrollment and service capacity are losing share in California, Texas, Florida, Arizona, and the Northeast. Two factors drive this:

• Demographic and growth math. More than 5 million Hispanic beneficiaries are Medicare-eligible today. Hispanic MA enrollment growth runs roughly 4 times the overall MA growth rate, and AEP is the highest-leverage window to win or lose those beneficiaries.
• Star Ratings impact. CMS Star Ratings include CAHPS member experience measures in Spanish. Plans that route Hispanic members to a third-party language line for AEP enrollment routinely score worse on member experience than plans with native Spanish-speaking licensed agents.

The traditional onshore answer (US-based bilingual agents) is the most expensive labor pool in the AEP market. The nearshore answer (native Spanish-speaking AHIP-certified agents in Colombia, plus Spanish-fluent agents in the Caribbean) gives carriers the bilingual capacity at a 50 to 60 percent cost reduction with no Star Ratings tradeoff. For a deeper look at the model, see our guide on bilingual customer support outsourcing.

Nearshore vs Offshore for Medicare

Offshore Philippines and India operations are generally not used for Medicare AEP. CMS recording infrastructure, PHI cross-border concerns, brand-trust optics, and the FCC's March 26, 2026 offshore NPRM all complicate offshore Medicare. Nearshore Caribbean and Latin American operations are the dominant model.

Healthcare BPO buyers ask the offshore question every year because the labor cost gap is real. For Medicare AEP specifically, the answer is consistent: nearshore is the default. Five reasons:

• CMS recording and retention. The 10-year retention rule requires infrastructure that survives CMS audits. Offshore providers can technically meet this, but the data residency questions are harder when PHI flows through Manila or Bangalore.
• PHI cross-border concerns. Carriers run their own legal review of any PHI-handling jurisdiction. Caribbean and LATAM jurisdictions are routinely cleared. India and Philippines often face additional scrutiny.
• Brand-trust optics. Beneficiaries are more sensitive to perceived offshore handling than commercial customers. AEP is the highest-stakes 54 days of the year for retention.
• Time zone alignment. Caribbean and LATAM operations sit in Eastern and Central time zones. Real-time supervision, escalation, and same-day QA review work the way they would with a US-based team.
• FCC offshore NPRM. The FCC adopted an NPRM on March 26, 2026 that would require offshore call centers to disclose location, offer transfer to a US-based representative on request, and meet English proficiency standards. For Medicare, layering those disclosures on top of the CMS TPMO disclaimer creates scripting complexity and Star Ratings exposure most carriers want to avoid. Our full breakdown is in FCC offshore call center restrictions: 2026 buyer guide.

The result is that the AEP labor market has consolidated. Onshore for a smaller core team, nearshore Caribbean and Colombian operations for the bulk of the surge. Offshore plays a much smaller role than it did in 2020, and most carriers we talk to have either eliminated or sharply reduced offshore Medicare exposure for the 2027 plan year.

Pre-AEP Timeline: May Through September

May: vendor selection and contracting. June: AHIP release and recruiting kickoff. July: state licensing, AHIP completion, and carrier onboarding. August: plan-specific training and secret shopper readiness. September: full ramp, dry runs, and final compliance audits.

May 2026: Vendor Selection and Contract

Issue your AEP RFP, score vendors on licensed-agent retention, AHIP pass rates, state licensing throughput, and CMS compliance posture. Sign master service agreements and statements of work by May 31. Lock in seat counts, hourly rates, peak premiums, and quality SLAs. For RFP structure, our Medicare call center outsourcing pillar covers the vendor evaluation criteria in depth.

June 2026: AHIP Release and Recruiting Kickoff

AHIP releases the 2027 plan year certification module, typically late June. BPO partners begin recruiting new seasonal agents, returning-cohort recertification starts, and state license applications go out for any non-licensed new hires. Carriers send plan materials and training calendars.

July 2026: Licensing, AHIP, Carrier Onboarding

State licensing exams. AHIP completion across the full surge cohort. Carrier-specific onboarding kicks off: system access, recording integration, CMS scripting review. Returning agents complete the new-year carrier deltas. New agents progress through baseline product training.

August 2026: Plan-Specific Training and Secret Shopper Readiness

Plan-specific training across all carriers and plans the agent will sell. SOA workflow drills. TPMO disclaimer mastery. Mock secret shopper calls scored against CMS rubrics. Compliance team audits scripting and recording integration. Most carriers require certification sign-off by August 31 or September 15.

September 2026: Full Ramp, Dry Runs, Final Audits

Full surge cohort on the floor by September 15 to October 1. Dry-run inbound and outbound shifts at 50 to 70 percent of expected AEP volume. Side-by-side QA and supervisor coverage. Final CMS compliance audit. Real-time dashboards live and tied to your CRM and your CMS reporting feed.

October 1 to October 14: Soft Launch

The 2 weeks before AEP opens are used for T-65 outreach, plan review calls into the existing book, and final scripting tweaks. October 15 hits with your team already warm.

How CFG Fits

Call Force Global runs nearshore AHIP-certified, state-licensed Medicare teams from Jamaica, Trinidad, and Colombia. Native English plus native Spanish bilingual capacity, 40 to 60 percent cost vs onshore licensed teams, and surge ramp capacity sized for AEP carriers and FMOs.

CFG is a Toronto-headquartered nearshore BPO running operations in Jamaica, Trinidad, and Colombia. We were founded in 2025 and our core focus is regulated voice work, with Medicare AEP as one of our most demanding workload categories. For AEP carriers and FMOs we run AHIP-certified, state-licensed inbound enrollment teams, outbound T-65 and aging-in outreach, member onboarding, and post-enrollment care navigation.

The model we run for Medicare clients:

• AHIP and state licensing pipeline. Recruiting starts in February for returning cohorts, March for new agents. AHIP completion runs July through August. State licensing parallel to AHIP.
• Native English (Caribbean) plus native Spanish (Colombia). Bilingual coverage without third-party language lines.
• CMS-compliant recording and retention. 10-year retention infrastructure with audit-ready retrieval.
• 40 to 60 percent cost vs onshore. Fully loaded $14 to $22/hr range for licensed AEP agents.
• Surge ramp. We size and recruit for the curve, not a flat headcount.

Our Medicare service page details the full scope and the contracting process. For buyers comparing nearshore options, our healthcare call center outsourcing guide covers the broader regulated-voice infrastructure.

Risks of Waiting

Vendor capacity for licensed Medicare seats sells out by August in most years. Plan-specific training takes 4 to 6 weeks per agent. Star Ratings hits from poor AEP CX compound for the next plan year, depressing CMS quality bonus payments.

The cost of contracting late is mostly hidden until you try to do it. Three failure modes we see every year:

• Capacity sells out. By August, the BPO providers with serious AHIP and state-licensing capacity are committed. Late buyers get either smaller teams than they need, or BPO partners with weaker compliance posture.
• Training compresses, quality drops. If you contract in August for an October launch, your agents are completing AHIP, state licensing, and plan training in parallel. They hit the floor under-trained, secret shopper failure rates spike, and CMS marketing violations follow.
• Star Ratings hits compound. Marketing violations, complaint volumes, and member experience scores during AEP feed into next year's Star Ratings. A bad AEP becomes a bad 2028 quality bonus check, which becomes a smaller marketing budget for AEP 2027, which depresses next year's enrollment. The compounding is the part most CFOs underprice.

If your team has not started vendor selection yet, May is the latest comfortable window. June is workable for returning cohorts. July is tight. August, in our experience, is the month carriers learn that the BPO market has moved on without them.

Frequently Asked Questions