WASHINGTON, Jan. 29, 2026 /PRNewswire/ — The National Association of Benefits and Insurance Professionals (NABIP) recently submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) in response to the Contract Year (CY) 2027 Medicare Advantage and Part D proposed rule (CMS-4212-P), urging the agency to promote fair agent compensation, reduce unnecessary regulatory complexity, and address bad actors—without limiting beneficiary access to trusted, licensed guidance.
NABIP raised concerns about abrupt changes to agent compensation, particularly when carriers reduce or eliminate commissions shortly before or during the Annual Enrollment Period (AEP). These late-stage changes disrupt the market and undermine agents’ ability to assist beneficiaries during a critical decision-making period.
“Agents and brokers are often the most trusted resource Medicare beneficiaries rely on to navigate complex coverage choices,” said Jessica Brooks Woods, CEO of NABIP. “When compensation structures change with little notice—especially during AEP—it threatens beneficiaries’ access to personalized guidance and creates instability in the marketplace.”
Building on NABIP’s recent engagement with state Departments of Insurance to address market disruption tied to commission eliminations, the association urged CMS to improve stability by discouraging changes after October 1 to plan availability on electronic enrollment platforms and to agent commission structures. Aligning these policies with plan finalization timelines would help ensure continuity for agents and uninterrupted access to guidance.
NABIP also supported CMS’s efforts to address bad actors while avoiding unnecessary burdens on compliant agents and organizations. The association recommended streamlining marketing rules, establishing clearer guardrails for lead generation entities, and improving coordination with the Federal Trade Commission (FTC) and Federal Communications Commission (FCC) to more effectively combat deceptive marketing practices.
NABIP expressed support for proposed policy changes that would enhance beneficiary access, reduce administrative friction, and improve data security, including removal of the 48-hour Scope of Appointment waiting period, expanded educational and sales event flexibilities, modifications to TPMO disclaimer requirements, clarifications to marketing language and Medicare card use, and updates to record retention rules.
NABIP looks forward to continuing to work with CMS as the agency finalizes the CY 2027 Medicare rule to strengthen beneficiary protections while preserving access to trusted, licensed guidance. NABIP’s full comment letter to CMS can be found here.
Press Contact:
Kelly Loussedes kloussedes@nabip.org
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SOURCE National Association of Benefits and Insurance Professionals
