If you work with Medicare Advantage or Prescription Drug Plans, you’ve likely asked: how often are Medicare Communications and Marketing Guidelines updated? The Centers for Medicare & Medicaid Services (CMS) updates these rules once every year, typically between April and June, before the Annual Election Period (AEP) begins each October.
As of November 2025, the latest version of the Medicare Communications and Marketing Guidelines (MCMG) was released in May 2025 for the 2026 plan year. The new update brings changes designed to make Medicare marketing more transparent, ethical, and senior-friendly in an era of rapid digital growth.
What the Medicare Communications and Marketing Guidelines (MCMG) Are
The MCMG is a set of federal rules that regulate how Medicare Advantage and Prescription Drug Plan organizations, agents, and third-party marketers advertise or communicate with potential enrollees.
These rules ensure that marketing messages are clear, honest, and not misleading — and that beneficiaries are protected from aggressive or deceptive sales tactics.
The MCMG applies to:
- Medicare Advantage (Part C) plans
- Prescription Drug (Part D) plans
- Medicare-Medicaid Plans (MMPs)
- Third-Party Marketing Organizations (TPMOs)
- Insurance agents and brokers who represent these plans
If you’re involved in marketing, selling, or even communicating about Medicare plan options, you’re required to follow these guidelines.
How Often Are Medicare Communications and Marketing Guidelines Updated?
CMS updates the MCMG every year, usually in spring or early summer, so organizations have time to review changes before the new plan year begins on January 1.
Here’s a look at the most recent update timeline:
| Year | CMS Release Date | Effective Plan Year | Key Focus Areas |
|---|---|---|---|
| 2023 | May 10, 2023 | 2024 | TPMO oversight and ad disclaimers |
| 2024 | May 30, 2024 | 2025 | Clearer definitions of marketing and communication |
| 2025 | May 15, 2025 | 2026 | Digital marketing, AI guidance, and compliance updates |
While the main update occurs once per year, CMS can also issue mid-year memos if new regulations, technologies, or compliance problems arise. However, those memos are usually clarifications rather than full revisions.
Why CMS Updates the MCMG Every Year
Healthcare and marketing are constantly evolving. New technologies, communication platforms, and even scams appear every year, and CMS must adapt to protect Medicare beneficiaries.
The annual update process ensures that:
- Marketing stays ethical and accurate — eliminating misleading or manipulative tactics.
- New technology is regulated — including AI, social media ads, and lead-generation sites.
- Agents and brokers receive clarity on evolving compliance requirements.
- Beneficiaries remain protected from deceptive or confusing information.
Each update builds on feedback from audits, industry complaints, and emerging trends in marketing and consumer behavior.
What Changed in the 2025 MCMG (For 2026 Plan Year)
The May 2025 version of the MCMG brought several important changes, especially related to digital marketing, artificial intelligence, and transparency.
Here are the most notable updates:
1. New Oversight for Digital and AI-Driven Marketing
CMS now regulates AI-generated marketing content, such as automated chatbots, email responses, or voice tools. All AI systems must provide accurate, non-deceptive information and clearly disclose that users are interacting with an automated system.
Digital ads, social media posts, and online lead forms must also include clear disclosures about the plan sponsor or marketing organization responsible for the content.
2. Revised Definitions for “Marketing” vs. “Communication”
CMS updated the definitions to help agents and organizations understand what requires CMS approval:
- Marketing: Content meant to influence enrollment decisions (requires CMS review).
- Communication: Informational content not tied to enrollment decisions (no review needed).
This distinction helps reduce confusion when developing ads, emails, or event materials.
3. Stronger Rules for Third-Party Marketing Organizations (TPMOs)
TPMOs must now record all marketing calls, video meetings, and chat interactions with potential enrollees. These recordings must be kept for 10 years and made available during CMS audits.
4. Clearer Rules on “Medicare-Approved” Language
CMS has restricted the use of phrases like “Medicare-endorsed,” “Medicare-certified,” or “official Medicare plan.” Such language is prohibited unless the organization has explicit CMS approval.
5. Educational Events and Scope of Appointment (SOA)
Educational events can only share general Medicare information — not specific plan details. Collecting contact information for future marketing during these events is strictly prohibited.
Additionally, Scope of Appointment (SOA) rules were reinforced: agents must secure and retain an SOA form before discussing any plan benefits and keep it on record for 10 years.
Who Must Follow These Guidelines?
Anyone involved in marketing or communicating about Medicare Advantage or Part D plans must comply with the MCMG, including:
- Insurance carriers and plan sponsors
- TPMOs and subcontractors
- Independent agents and brokers
- Call centers, marketing vendors, and digital ad agencies
Even organizations that only generate leads — but don’t directly sell plans — fall under CMS’s marketing oversight if their activities influence Medicare enrollments.
When CMS Issues Mid-Year Clarifications
While the official MCMG is updated once a year, CMS sometimes releases mid-year memos to address urgent issues.
These may include:
- New legislation impacting Medicare marketing
- Widespread non-compliance issues
- Technological changes like new ad platforms or data-collection tools
For instance, in late 2024, CMS issued an interim memo on AI-based marketing tools, reminding organizations that using chatbots or automated calls must still comply with disclosure and accuracy standards.
These interim memos are meant to guide organizations until the next full guideline release.
Why Staying Updated Is So Important
Understanding how often and when the MCMG is updated helps organizations maintain compliance and avoid serious penalties. CMS takes violations seriously — even unintentional ones — because they can mislead seniors.
Here’s why staying up-to-date matters:
- Avoid penalties and sanctions: CMS can fine organizations or revoke their ability to market plans.
- Ensure accurate marketing materials: Outdated disclosures or claims can be deemed misleading.
- Protect your reputation: Compliance demonstrates professionalism and ethical integrity.
- Prepare early for AEP: Knowing the changes in advance allows enough time for material updates.
Agents, carriers, and marketing teams who stay informed are better equipped to build trust and stay compliant.
How to Stay Informed About MCMG Updates
To keep up with CMS guideline updates, here are a few practical steps:
- Check the CMS website (CMS.gov) regularly for new guideline releases.
- Subscribe to CMS newsletters and compliance bulletins.
- Attend compliance webinars hosted by carriers or industry associations.
- Review HPMS memos (Health Plan Management System updates).
- Work with compliance officers or legal teams to ensure materials meet CMS requirements.
Most agencies begin reviewing and updating their marketing content within 30 days of a new MCMG release to stay ahead of compliance deadlines.
What the Future of MCMG Updates May Look Like
As Medicare marketing continues to evolve, CMS is expected to expand its oversight into emerging technologies and online marketing tactics. Future guideline updates may include:
- Stricter rules on AI-driven personalization and data collection.
- New reporting requirements for digital ad targeting.
- Tighter restrictions on influencer or social media marketing in Medicare.
- Enhanced privacy protections for beneficiary data.
These potential updates reflect CMS’s ongoing effort to balance innovation with consumer protection in an increasingly digital marketplace.
Final Thoughts: Staying Compliant Through Awareness and Preparation
So, how often are Medicare Communications and Marketing Guidelines updated? The answer is simple: once a year, with occasional memos when necessary. But these updates are more than administrative — they’re essential to keeping Medicare marketing honest, accurate, and focused on beneficiaries.
For anyone working in Medicare sales, compliance, or advertising, staying informed about annual updates isn’t optional — it’s the key to maintaining trust, avoiding penalties, and delivering ethical service to seniors.
Have you reviewed the 2025 MCMG updates yet? Let us know in the comments which changes you think will have the biggest impact in the upcoming plan year!