Sort Medicare leads with a small set of tags for plan type, a field for the permission to contact date, and Smart Lists for each segment, all in GoHighLevel. Then run workflows only for leads who gave permission. The bottom line: the sorting is easy, and the compliance is the work, because Medicare marketing rules restrict who an agent may contact and how, and the rules change October 1, 2026, two weeks before the Annual Enrollment Period opens.
The rules, as of September 30, 2026
The Annual Enrollment Period runs October 15 to December 7. CMS's Contract Year 2027 final rule, announced April 2, 2026, includes removing restrictions on the time and manner of conversations between beneficiaries and licensed agents and brokers. Trade summaries say it eliminates the 48 hour waiting period between a completed Scope of Appointment and a personal marketing appointment, effective for contract year 2027 marketing beginning October 1, 2026, and leaves the prohibition on unsolicited telephone solicitation of beneficiaries in place. Under the summaries, a call is not unsolicited if the beneficiary consents or initiates contact. A California brokers' magazine reports the 12 month limit on scope of appointment and permission to contact records. Carriers add their own rules on top, so confirm each one before you build.
This is general information, not compliance advice. The federal rule text and your carriers' contracting guidelines govern, and a Medicare compliance professional should review your process.
Tags and fields
| Tag or field | Values |
|---|---|
| Plan interest | Medicare Advantage, Advantage with drug, Part D, Medigap, Dual eligible |
| Stage | New to Medicare, Turning 65 soon, Current plan holder |
| Current carrier | Text |
| Permission to contact date and source | Date, and the form or call that gave permission |
| Permission expires | Permission date plus 12 months |
| Effective date of current plan | Date |
Keep drug lists, doctors, and health conditions out of the CRM's texts and tags. Collect those in the appointment.
Build it in GoHighLevel
- Create the fields in the table under Settings, then Custom Fields.
- Add a permission to contact question to every lead form, with a checkbox, and have the form workflow set the Permission date and add a tag.
- Create a Smart List for each plan interest, and one for leads whose permission expires in the next 30 days. GoHighLevel's Smart Lists are saved, self updating filtered views, according to a third party guide.
- Build a workflow for each segment that sends an AEP preparation message, starting only for contacts with the permission tag.
- Build a workflow with the Custom Date Reminder trigger on Permission expires, 30 days before, that asks the lead to renew permission.
- Add the required TPMO disclaimer to emails and your website, in the exact words your compliance team specifies.
- Set a Time Window and turn on Stop on Response.
GoHighLevel's Custom Date Reminder page says the trigger fires before, on, or after a date, that in contact based workflows you can choose supported contact date fields and supported opportunity date fields, that it does not fire for a contact whose date field is empty, and that a workflow can hold two triggers, one before and one after the date. It also describes a Match on the year option for reminders that repeat every year, so read that setting's description in your account and test it with a real date field.
GoHighLevel's Workflow Settings page says Stop on Response removes a contact from the workflow when they respond to a message sent from that workflow, and only for that contact. It says Allow Reentry controls whether a contact can enter again, that Allow multiple Opportunities lets each of a contact's opportunities start its own run (on by default in new workflows), that the Timezone can follow the account or the contact, and that the Time Window restricts when communications go out, uses one window for every day, and does not affect internal actions such as tags, fields, or opportunities. Its Automating Opportunities page lists the Pipeline Stage Changed and Opportunity Status Changed triggers, both filterable by standard and custom opportunity fields, and its Opportunity Changed trigger page adds that this trigger also detects changes to lead value, assignment, and custom fields, with date field filters. A HighLevel agency help center article says opportunity custom fields are created under Settings, then Custom Fields.
What the workload looks like
For example, an agent with 1,200 leads across five plan interests has five segments of about 240 (1,200 divided by 5). Sending each segment its own preparation message takes one workflow per segment, instead of one message to everyone.
Mistakes to avoid
- Contacting leads with no permission on file. Unsolicited calls are barred under the summaries.
- Using an expired permission. Records are limited to 12 months.
- Collecting health details in texts. Use the appointment.
- Skipping the carrier rules. They can be stricter than CMS.
How this was handled before
Agents kept lead lists by source and called down them in the fall. Rules about who may be called, and on what basis, have tightened and changed year to year, so a list sorted only by source is a risk. Sorting by plan interest and permission date gives the agent a list that answers both questions.
Check before you switch it on
US text messages sent from a standard 10 digit number need A2P 10DLC registration. The HighLevel support portal says registration is required for texts to US recipients from 10 digit long code numbers and that toll free numbers do not require it. HighLevel's opt in guidelines also say a person cannot be forced to agree to text messages in order to submit a form, so keep the consent box optional. One compliance guide separates informational texts, which need documented consent, from marketing texts, which need prior express written consent. Ask your attorney which category your reminders fall into. Medicare beneficiaries are often older adults who prefer a phone call, so ask how they want to be contacted. This is general information, not legal advice.
Questions people ask
When is the Annual Enrollment Period?
October 15 to December 7.
What changes on October 1, 2026?
Trade summaries of CMS's Contract Year 2027 final rule say the 48 hour Scope of Appointment waiting period is eliminated, and the telephone solicitation prohibition stays. Check the rule text and your carriers.
How long does permission to contact last?
A California brokers' magazine reports a 12 month limit on scope of appointment and permission to contact records.
Ready to try it yourself? Start a GoHighLevel account here.
You can also see this in action in our GoHighLevel capabilities demo.