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Medicare and ACA season: using calculators without tripping CMS and marketplace rules

Using calculators during AEP and open enrollment: key dates, TPMO disclaimer, scope-of-appointment timing, and the 2026 return of the 400% FPL limit.

Key takeaways

  • Medicare's Annual Enrollment Period runs October 15 to December 7; HealthCare.gov open enrollment generally runs November 1 to January 15. Many agencies work both at once.
  • Medicare Advantage and Part D marketing is governed by CMS rules, including the TPMO disclaimer and scope-of-appointment requirements. CMS's CY2027 final rule changed scope-of-appointment timing, so check current CMS guidance before AEP.
  • Calculators should be educational and plan-neutral. Estimating a cost or a savings need is not the same as comparing or recommending specific plans.
  • The ACA's enhanced premium tax credits expired after 2025. For 2026 coverage the 400% of federal poverty level limit is back, which changes conversations for many households.
  • HSA calculators are a strong pre-Medicare and employer-season tool, but HSA contributions stop once someone enrolls in Medicare.

General information for agencies, not legal or compliance advice. CMS guidance, marketplace rules and state requirements change every year; confirm current rules with your compliance contact and the carriers you are appointed with.

Autumn is the busiest stretch on the health side of an agency's calendar. Medicare's Annual Enrollment Period and the ACA marketplace's open enrollment overlap for several weeks, employer benefits elections run at the same time, and every one of those conversations has its own rulebook. Calculators can help by handling the education and leaving the producer with the regulated parts. They can also create problems if they drift into plan comparisons or appear on pages that miss required disclosures. This guide covers how to use them well this season.

What are the key enrollment dates this season?

Medicare's Annual Enrollment Period runs October 15 to December 7. HealthCare.gov open enrollment generally runs November 1 to January 15, though state-run marketplaces may differ. The Medicare Advantage Open Enrollment Period follows from January 1 to March 31. Employer open enrollment dates vary by employer.

WindowTypical datesWho it affectsLive calculators that help
Medicare Annual Enrollment PeriodOctober 15 – December 7People with Medicare changing MA or Part D coverageLong-term care, immediate annuity for broader retirement planning (not plan selection)
HealthCare.gov open enrollmentGenerally November 1 – January 15Individual-market buyersHSA vs traditional plan where HSA-eligible plans are on the table
Medicare Advantage Open EnrollmentJanuary 1 – March 31People already in Medicare AdvantageSame as AEP
Employer benefits electionsSet by each employerWorking households, including those nearing 65HSA contribution, HSA savings, HSA vs traditional plan
Turning 65Individual timelineNew-to-Medicare clientsHSA contribution (contributions stop at Medicare enrollment)

Source: HealthCare.gov's dates and deadlines page and CMS (checked October 2026). State marketplace dates may differ, and special enrollment periods exist outside these windows.

What CMS rules apply to Medicare marketing on agency websites?

When you market Medicare Advantage or Part D plans, CMS's marketing rules apply to your website, lead forms, calls and follow-up. They include the TPMO disclaimer, scope-of-appointment requirements before discussing plan types in a sales appointment, limits on how and when beneficiaries may be contacted, and rules about what materials must say.

The governing sources are the Medicare Communications and Marketing Guidelines published by CMS and the regulations at 42 CFR Part 422, Subpart V (and the parallel Part 423 provisions for Part D). We link both in the sources. Three areas matter most for a calculator page:

The TPMO disclaimer

Third-party marketing organizations, which include many independent agencies and brokers, must use a CMS-specified disclaimer stating that they do not offer every plan available in the beneficiary's area, and pointing to official sources of information. The regulation and guidelines set out the content and where it must appear, including websites and certain phone calls. Use the current wording from CMS rather than a version copied from another site, because the required content has changed in recent years.

Scope of appointment

Before a sales appointment about Medicare Advantage or Part D, agents must document the scope of the appointment: which product types the beneficiary agreed to discuss. For years agents worked with a waiting period between documenting scope and holding the appointment, subject to exceptions. CMS's CY2027 final rule changed the scope-of-appointment timing requirements. Because the effective date and details matter, check the current CMS guidance and regulation text before AEP, and align your workflow with what your carriers require.

Contact rules

CMS restricts unsolicited contact with beneficiaries and sets rules for following up on inquiries. A calculator lead form is an inquiry, but what the beneficiary asked about defines what you may follow up on. If someone ran a long-term care estimate, that does not by itself invite a Medicare Advantage sales call. TCPA consent applies on top; see our TCPA consent guide.

How do calculators stay plan-neutral?

A plan-neutral calculator estimates a household's own figures — a savings target, a contribution limit, a care-cost gap — without naming plans, carriers, premiums or benefits. It educates rather than compares. Plan comparisons and recommendations belong in a documented appointment with a licensed, appointed agent, under CMS and carrier rules.

Every InsuranceQuoteWidget calculator is educational and produces an estimate, not a quote. None of the live calculators compares Medicare plans, and none displays carrier names. That keeps the tool itself on the educational side of the line. Your page around it still needs the right disclosures.

The NEUTRAL page check

Before AEP, review every page where a calculator sits near Medicare content:

  • N — No plan names in the calculator, its headline or its result text.
  • E — Educational framing. The page explains a concept (care costs, HSA rules) rather than pitching a plan.
  • U — Up-to-date disclaimer. The current TPMO disclaimer appears where CMS requires it, if you are a TPMO.
  • T — Topic-limited follow-up. The lead form and follow-up stay within what the visitor asked about.
  • R — Recorded consent. Consent language covers your actual outreach methods and is stored with the lead.
  • A — Appointment documentation. Your scope-of-appointment process reflects current CMS timing rules.
  • L — Licensed and appointed. The agents who follow up are licensed in the beneficiary's state and appointed with the relevant carriers.

Which calculators help Medicare-age clients right now?

Today's live tools support the planning conversations around Medicare rather than plan selection: long-term care costs, turning savings into income, and HSA rules for people still working near 65. A Medicare IRMAA calculator is coming, and will be added when it is released.

  • Long-term care calculator — projects Future Annual Cost, Total Future Care Cost and a Funding Gap against Savings Set Aside. It is a natural follow-up for clients who assume Medicare covers extended custodial care; the income protection hub explains how agencies use it.
  • Immediate annuity calculator — estimates Monthly Income from a Lump-Sum Premium over a fixed payout period. Annuity sales carry their own suitability rules; see our annuity suitability guide.
  • HSA contribution calculator — shows the year's maximum, including the age-55 catch-up, and accounts for the fact that the limit drops to zero once someone enrolls in Medicare.

The Medicare hub groups these related tools. Keep them away from pages that present specific plans, and keep their follow-up on topic.

What changed for ACA premium tax credits in 2026?

The enhanced premium tax credits that began in 2021 and were later extended expired after 2025. For 2026 coverage, eligibility returns to the original structure: households with income above 400% of the federal poverty level generally cannot receive premium tax credits, and credit amounts for others follow the original formula.

For agencies this changes several conversations at once:

  • Households just above the 400% line may face their full premium for the first time in several years. They may want to look at different metal levels, HSA-eligible plans or employer options.
  • Self-employed clients whose income fluctuates around the threshold need careful income estimates, because crossing it can change eligibility entirely. Encourage them to work with a tax professional.
  • Renewal shock can reach clients who did nothing wrong. Starting the conversation early, with clear explanations, beats a surprised phone call in January.

Use HealthCare.gov's federal poverty level glossary page for current figures, and avoid quoting specific percentages or dollar amounts unless you have the official source in front of you (checked October 2026). The ACA premium tax credit calculator estimates the credit from household size, income and the benchmark silver premium, and the HSA vs traditional plan calculator helps households compare the total cost of an HSA-qualified plan with a traditional plan, using their own premiums, deductibles and expected medical costs. Its disclaimer notes the simplifications: it assumes the plan pays fully after the deductible and does not model coinsurance or out-of-pocket maximums.

How do HSA calculators fit employer and individual seasons?

HSA calculators help working households decide whether a high-deductible plan makes sense and how much to contribute. The IRS set the 2026 HSA contribution limits at $4,400 for self-only and $8,750 for family coverage (IRS Rev. Proc. 2025-19), plus a $1,000 catch-up from age 55. Contributions stop once someone enrolls in Medicare.

Three live tools cover the sequence of decisions:

DecisionCalculatorKey result
Is an HSA-qualified plan cheaper for us this year?HSA vs traditional planHSA Plan Net Cost vs Traditional Plan Net Cost, Annual Savings, HSA Tax Savings
How much can I still put in this year?HSA contributionMaximum Contribution, Remaining You Can Contribute, Monthly to Reach Max
What could this grow to?HSA savingsFuture HSA Value, Total Growth

The turning-65 conversation is where these become Medicare-adjacent. A client still working at 65 may be weighing whether to delay Medicare Part B and keep contributing to an HSA. That is a tax and enrollment question with real consequences; the calculator shows the contribution math, and the producer should point the client to a tax professional and official Medicare resources for the enrollment decision. See the health hub for how these tools are grouped.

How should the follow-up workflow differ by line this season?

Separate Medicare, ACA and employer-benefit leads into different workflows, because the permitted follow-up, required documentation and timing differ. Medicare leads need scope-of-appointment handling and TPMO disclosures; ACA leads need income and eligibility conversations; HSA leads are often benefits-education conversations that may never become a sale.

Practical setup:

  1. Tag by calculator and line when the lead arrives, so routing is automatic. If you run follow-up in HighLevel, our guide to sending calculator leads into HighLevel shows the tagging.
  2. Gate Medicare follow-up behind your scope-of-appointment process. Automated messages should acknowledge the inquiry and offer an appointment, not pitch plans.
  3. Keep a single suppression flag across lines, so an opt-out on one line is respected everywhere.
  4. Route by license. Leads from states where no one on your team is licensed should not reach a producer's queue.
  5. Track attribution. The lead's UTM tags and first-touch source tell you which seasonal campaign earned it; lead attribution explains the fields.

What is the pre-AEP calculator checklist?

Review every page that combines calculators and Medicare or ACA content against current CMS and marketplace rules, confirm disclaimers and consent language, update scope-of-appointment steps for the CY2027 changes, and brief producers on the 2026 premium tax credit changes before the phones get busy.

Season checklist

  1. Pull the current CMS Medicare Communications and Marketing Guidelines and note anything new since last season.
  2. Update the TPMO disclaimer on your site and call scripts to current CMS wording, if you are a TPMO.
  3. Re-document your scope-of-appointment process to reflect the CY2027 timing changes and carrier requirements.
  4. Run every calculator page through the NEUTRAL check.
  5. Confirm consent language on every lead form covers how you will actually follow up; see lead consent.
  6. Brief producers on the expired enhanced premium tax credits and the 400% FPL limit for 2026.
  7. Check HSA calculators reflect the current year's IRS limits.
  8. Separate Medicare, ACA and HSA follow-up workflows.
  9. Confirm license and appointment coverage for every state you advertise in.
  10. Record who reviewed the pages and when, for your compliance file.

The compliance overview collects our notes on these topics. Insurance calculators are included on every plan today, starting with the free Producer plan; compare plans if you want them live before the season peaks.

InsuranceQuoteWidget is a software company, not an insurance agency, broker or TPMO. We do not quote, sell, enroll or bind insurance, and our calculators are educational and plan-neutral. Licensing varies by state.

Sources

  1. CMS, Medicare Communications and Marketing Guidelines — checked October 17, 2026
  2. eCFR, 42 CFR 422.2267 (required materials and content, including the TPMO disclaimer) — checked October 17, 2026
  3. eCFR, 42 CFR 422.2264 (beneficiary contact, including scope of appointment) — checked October 17, 2026
  4. HealthCare.gov, Dates and deadlines — checked October 17, 2026
  5. HealthCare.gov glossary, Federal poverty level — checked October 17, 2026
  6. IRS, Revenue Procedure 2025-19 (2026 HSA limits) — checked October 17, 2026
  7. IRS Publication 969, Health Savings Accounts — checked October 17, 2026
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By

InsuranceQuoteWidget Editorial Desk

The editorial desk writes the guides on this site: how agencies pre-qualify prospects, run compliant lead forms and use needs calculators by line of business.

#Medicare#AEP#ACA open enrollment#TPMO disclaimer#Scope of appointment#HSA

FAQ

Questions agencies ask

Answers first, details after.

When is the Medicare Annual Enrollment Period?

The Medicare Annual Enrollment Period runs from October 15 to December 7 each year, with changes generally effective January 1. There is also a separate Medicare Advantage Open Enrollment Period from January 1 to March 31 for people already in a Medicare Advantage plan.

When is ACA open enrollment on HealthCare.gov?

On HealthCare.gov, open enrollment generally runs from November 1 to January 15, with coverage start dates depending on when someone enrolls. States that run their own marketplaces may set different deadlines, so check the state exchange for your market.

Can we use a calculator on a Medicare marketing page?

Generally, educational and plan-neutral tools can sit on an agency site, but the surrounding page, lead form and follow-up are subject to CMS marketing rules when you market Medicare Advantage or Part D plans. Keep calculators free of plan names and benefit comparisons, and have your compliance contact review the page.

What is the TPMO disclaimer and where does it go?

Third-party marketing organizations that market Medicare Advantage or Part D plans must use a CMS-required disclaimer explaining that they do not offer every plan available in the area. CMS specifies the content and where it must appear, including on websites and in certain calls. Use the current wording from CMS guidance.

Did the scope-of-appointment rules change for 2027?

Yes, CMS's CY2027 final rule changed the timing requirements for scope-of-appointment documentation. Because the details and effective dates matter, check the current CMS Medicare Communications and Marketing Guidelines and the regulation text before AEP rather than relying on last year's process.

What changed for ACA premium tax credits in 2026?

The enhanced premium tax credits first expanded in 2021 expired after 2025. For 2026 coverage, households with income above 400% of the federal poverty level are generally no longer eligible for premium tax credits, and credit amounts for others follow the original formula. Check HealthCare.gov for current figures.

Can people on Medicare contribute to an HSA?

No. Once someone enrolls in Medicare, their HSA contribution limit drops to zero, although they can still use existing HSA funds for qualified expenses. The HSA contribution calculator reflects this. Turning-65 clients who are still working should review timing with a tax professional.

Are Medicare IRMAA or ACA tax credit calculators available?

Yes. The Medicare IRMAA calculator estimates Part B and Part D surcharges from filing status and income, and the ACA premium tax credit calculator estimates the monthly Marketplace credit. Both produce estimates only; the Social Security Administration and the Marketplace make the actual determinations.

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