Many healthcare professionals, agents, and insurers often ask, “how often are Medicare Communications and Marketing Guidelines updated?” The answer is that the Centers for Medicare & Medicaid Services (CMS) typically updates the Medicare Communications and Marketing Guidelines (MCMG) annually—usually before each Medicare Advantage (MA) and Part D plan year begins on January 1. As of November 2025, the most recent updates were issued in May 2025, outlining new standards for marketing, digital outreach, and agent compliance for the 2026 plan year.
These guidelines serve as the foundation for how Medicare Advantage and Prescription Drug Plan sponsors, as well as third-party marketing organizations (TPMOs), communicate with Medicare beneficiaries. Understanding how frequently the MCMG is updated—and what those updates include—is critical for compliance and ethical marketing practices.
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What Are the Medicare Communications and Marketing Guidelines (MCMG)?
The MCMG is an official set of rules developed by CMS to ensure that all communications and marketing activities targeting Medicare beneficiaries are truthful, accurate, transparent, and compliant with federal law.
These guidelines apply to:
- Medicare Advantage (MA) organizations
- Part D prescription drug plan sponsors
- Medicare-Medicaid Plans (MMPs)
- Third-Party Marketing Organizations (TPMOs)
- Agents and brokers who represent or market these plans
The MCMG defines what constitutes marketing versus communication, outlines requirements for disclosures, sets rules for television, digital, print, and in-person advertising, and provides standards for beneficiary contact.
How Often Are Medicare Communications and Marketing Guidelines Updated?
CMS updates the MCMG once each year, typically in the spring or early summer, before the start of the Annual Election Period (AEP), which runs from October 15 to December 7.
Here’s a timeline showing the typical update cycle:
| Year | CMS MCMG Release Date | Plan Year Effective Date |
|---|---|---|
| 2023 | May 10, 2023 | 2024 |
| 2024 | May 30, 2024 | 2025 |
| 2025 | May 15, 2025 | 2026 |
This pattern allows Medicare Advantage and Part D sponsors, agents, and TPMOs several months to adjust their marketing materials and communication strategies before AEP begins.
Occasionally, CMS issues mid-year memoranda or clarifications, particularly when new laws or emerging marketing practices require immediate attention. However, the comprehensive guideline revision happens only once per year.
Why CMS Updates the MCMG Every Year
The healthcare and insurance landscape changes rapidly—new marketing technologies emerge, compliance violations occur, and regulations evolve to protect beneficiaries. CMS updates the MCMG annually to:
- Reflect policy changes under new federal healthcare laws or executive actions.
- Address compliance concerns uncovered through audits or complaint investigations.
- Adapt to technological changes, such as online lead generation and social media marketing.
- Clarify definitions of communications and marketing to prevent misleading practices.
- Enhance beneficiary protection, ensuring seniors receive accurate and unbiased information.
By updating these guidelines regularly, CMS ensures that marketing efforts stay ethical, consistent, and beneficiary-focused.
Key Changes in the 2025 MCMG (Effective for 2026 Plan Year)
The May 2025 version of the MCMG introduced several notable revisions to improve transparency and beneficiary protection. These updates reflect CMS’s ongoing efforts to regulate marketing activity, especially in digital spaces.
Some of the most significant updates include:
1. Stricter Digital Marketing Rules
CMS expanded definitions around digital and online marketing, including social media, video ads, and lead-generation websites. TPMOs must now clearly disclose their relationship to Medicare Advantage plans in all digital advertisements.
2. Enhanced Third-Party Marketing Oversight
Third-party marketers are required to record all sales calls and retain them for 10 years. They must also submit new scripts and online ad materials to CMS-approved channels before public distribution.
3. Clarified Prohibitions on Misleading Phrases
Terms such as “Medicare-approved” or “official Medicare plan” are now restricted unless CMS explicitly authorizes their use.
4. Standardized Disclaimers
All marketing materials—including online ads and emails—must include the standardized disclaimer that clarifies the marketer’s relationship to Medicare and plan sponsors.
5. Reinforcement of In-Person Marketing Boundaries
Agents and brokers cannot engage in unsolicited door-to-door marketing. Appointments with beneficiaries must be pre-scheduled, and scope of appointment (SOA) documentation must be retained for 10 years.
These updates ensure that marketing remains fair, transparent, and compliant with federal law, especially as digital outreach continues to expand.
Who Must Follow the MCMG?
The MCMG applies to a broad range of organizations and individuals involved in Medicare-related marketing or communications. This includes:
- Medicare Advantage (Part C) plans
- Prescription Drug (Part D) plans
- Medicare-Medicaid Plans (MMPs)
- Third-Party Marketing Organizations (TPMOs)
- Agents and brokers contracted to represent plans
Even subcontractors or lead vendors working on behalf of TPMOs must comply. Failure to adhere can result in sanctions, fines, or loss of CMS approval.
What Happens If the Guidelines Change Mid-Year?
Although CMS primarily updates the MCMG annually, there are times when it issues interim memos or guidance during the year. These are typically triggered by:
- Regulatory changes, such as new federal rules affecting marketing practices.
- Widespread compliance violations discovered through audits.
- Emerging marketing trends, like artificial intelligence or influencer-based advertising.
In those cases, CMS provides official memoranda to clarify enforcement expectations, giving plans and agents time to adapt without disrupting the current AEP cycle.
For example, in late 2024, CMS issued an interim memo clarifying its position on AI-generated marketing content, reminding TPMOs that all materials must still meet existing accuracy and transparency standards.
Why Understanding Update Frequency Matters
For professionals working in Medicare marketing, knowing how often the MCMG is updated is essential for maintaining compliance and avoiding penalties.
Here’s why it matters:
- Compliance risk management: Staying informed helps agents avoid fines or revocation of certification.
- Accurate information: Outdated materials can mislead beneficiaries and violate federal rules.
- Operational efficiency: Early awareness allows organizations to update training, scripts, and marketing campaigns before AEP begins.
- Professional credibility: Following current CMS guidelines builds trust with both clients and regulators.
Failing to stay updated can result in serious consequences, including enforcement actions, loss of plan sponsorship, and damage to an organization’s reputation.
How to Stay Updated on the MCMG
Professionals in the Medicare space can stay informed about MCMG updates by:
- Subscribing to CMS communications through the Health Plan Management System (HPMS).
- Attending compliance webinars hosted by CMS or insurance carriers.
- Reviewing annual training materials provided by plan sponsors or Field Marketing Organizations (FMOs).
- Monitoring CMS.gov and official social media accounts for announcements.
- Collaborating with compliance departments to ensure all marketing materials are reviewed before use.
Early preparation is key. Most organizations begin revising their materials in June and July, immediately after CMS releases the new version of the guidelines.
The Future of Medicare Marketing Oversight
CMS has signaled that future updates will continue focusing on digital advertising, AI-generated content, and data privacy. As more Medicare marketing shifts online, regulators are tightening standards to ensure beneficiaries—especially seniors—are protected from misleading or aggressive advertising.
Industry experts expect the next few years to bring:
- Stricter tracking requirements for lead generation.
- New CMS reporting tools for online ad submissions.
- Expanded audit processes for TPMOs and agents.
The goal remains the same: to balance effective marketing with ethical communication that helps beneficiaries make informed coverage decisions.
Conclusion: Annual Updates Keep Medicare Marketing Transparent and Fair
So, how often are Medicare Communications and Marketing Guidelines updated? In most cases, once a year, with occasional mid-year clarifications. These regular updates are crucial for maintaining fairness, compliance, and transparency across the entire Medicare marketing ecosystem.
By staying informed and adjusting to new regulations, organizations and agents can continue serving beneficiaries with accuracy and integrity—values that remain at the heart of Medicare’s mission.
Have you reviewed the 2025 MCMG updates yet? Share your thoughts below or let us know which changes you think will impact Medicare marketing the most!
