When an SOA is required
CMS requires a documented Scope of Appointment for personal marketing appointments. The March 16, 2022 Medicare Communications and Marketing Guidelines, Scope of Appointment section, say it is documented for marketing activities including in person, by telephone, and for walk-ins to a plan or agent office. The guidelines page that links this PDF was last modified September 10, 2024.
Timing on that March 16, 2022 table is prior to the appointment. The same section says the form or the recorded call must include the product types to be discussed, the date of the appointment, beneficiary and agent contact information, and a statement that there is no obligation to enroll, that current or future Medicare enrollment will not be affected, and that automatic enrollment will not occur.
A new SOA is required if the beneficiary asks about a different plan type than the one already agreed. The March 16, 2022 guidelines do not list a separate menu of products that may be discussed outside that agreement. The limit they state is the product types on the form.
The 2027 timing rule
CMS's fact sheet, Changes to the Medicare Advantage Organization and Medicare Drug Plan Sponsors Marketing Guidelines, applies to contract year 2027 marketing and communications beginning October 1, 2026. It says plans may schedule a personal marketing appointment any time after an SOA form is completed, and may collect SOA forms at educational events. The fact sheet points to the April 6, 2026 final rule (Medicare Program; Contract Year 2027 Policy and Technical Changes). CMS has not posted a newer MCMG PDF than the March 16, 2022 file. Use that PDF for the form elements and the fact sheet plus the final rule for what changed in 2027.
That fact sheet does not keep a 48-hour wait, and it does not list exceptions to a 48-hour wait. The March 16, 2022 SOA table also does not state a 48-hour wait or exceptions. The 2027 rule in the fact sheet is the one to use: any time after the form is completed.
The same fact sheet says plans must retain sales and marketing call recordings for 6 years, down from 10 years. Transcripts may be used in place of recordings for years 4 through 6. The March 16, 2022 SOA table does not state a separate retention period for the form itself.
Electronic SOA
The March 16, 2022 guidelines list the method of delivery as a signed hard copy or an electronic form, and, for telephonic appointments, a telephonic recording. That electronic form is the electronic SOA (eSOA) in the current guidelines.
A licensed agent documents the Scope of Appointment in their own process before a personal marketing appointment. Rivvi does not record it, call the client, or book the appointment.