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Definition · Medicare marketing and compliance

Scope of Appointment (SOA)

An SOA is required before a personal marketing appointment, including in person, by phone, and for a walk-in. CMS still posts the March 16, 2022 Medicare Communications and Marketing Guidelines for the form's elements. For contract year 2027 marketing, starting October 1, 2026, the April 6, 2026 final rule and CMS's CY2027 marketing fact sheet say the appointment may happen any time after the form is completed. The form or the recorded call has to name the product types.

Download a 2027 SOA form (PDF)

Quick answers

Current CY2027 guidance

CMS still posts the March 16, 2022 Medicare Communications and Marketing Guidelines PDF. For contract year 2027 marketing, starting October 1, 2026, the April 6, 2026 final rule and CMS's CY2027 marketing fact sheet control the changes: no 48-hour wait, SOA forms may be collected at educational events, and sales call recordings are kept 6 years.

Source: CMS fact sheet: CY2027 marketing guideline changes

What the SOA must include

The product types to be discussed, the appointment date, the client's and the agent's contact information, and a statement that there is no obligation to enroll, that current or future Medicare enrollment won't be affected, and that automatic enrollment won't occur. The 2022 guidelines still list those elements. The CY2027 fact sheet changes timing, not that list.

Source: CMS fact sheet: CY2027 marketing guideline changes

When a new SOA is needed

When the client asks about a plan type that isn't on the SOA they already agreed to. The agent stays inside the product types on the form.

Source: CMS Medicare Communications and Marketing Guidelines, March 16, 2022

What is non-compliant

Holding a personal marketing appointment, in person, by phone, or for a walk-in, without a documented SOA. Discussing a plan type the client did not agree to on the form.

Source: CMS Medicare Communications and Marketing Guidelines, March 16, 2022

The 2027 timing change

For contract year 2027 marketing, starting October 1, 2026, the appointment can happen any time after the SOA is completed. There is no 48-hour wait, and plans may collect SOA forms at educational events. That change is in the April 6, 2026 final rule, summarized in CMS's CY2027 marketing fact sheet.

Source: CMS contract year 2027 Medicare Advantage and Part D final rule, April 6, 2026

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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.

Questions

Scope of Appointment, answered

Who needs a Scope of Appointment?
Anyone holding a personal Medicare marketing appointment. The March 16, 2022 Medicare Communications and Marketing Guidelines require a documented SOA for in-person appointments, telephone appointments, and walk-ins to a plan or agent office. The section cites sections 1851(j)(2)(A) and 1860D-04(l) of the Social Security Act and 42 CFR 422.2264(c) and 423.2264(c).
Is there a 48-hour wait before the appointment in 2027?
CMS's contract year 2027 marketing fact sheet says a personal marketing appointment may happen any time after the SOA form is completed. That fact sheet applies beginning October 1, 2026, and it cites the April 6, 2026 final rule. It does not list exceptions to a 48-hour wait. The March 16, 2022 guidelines time the SOA as prior to the appointment and do not state a 48-hour rule in the SOA table.
What is an electronic SOA?
In the March 16, 2022 guidelines, delivery may be a signed hard copy or an electronic form. For a telephone appointment, a telephonic recording may document it. Those guidelines, and the contract year 2027 fact sheet, do not define what a pending electronic SOA means.
What can be discussed?
The March 16, 2022 guidelines say the product types to be discussed must be on the SOA form or the recorded call. If the beneficiary wants information on a different plan type than the one agreed, a new SOA is required.
How long are the records kept?
CMS's contract year 2027 marketing fact sheet says sales and marketing call recordings are kept for 6 years, down from 10 years. Transcripts may replace the recordings for years 4 through 6. The March 16, 2022 SOA table does not give a separate retention period for the form.
Can an SOA be collected at an educational event in 2027?
Yes. The contract year 2027 marketing fact sheet says plans may collect SOA forms at educational events, for marketing beginning October 1, 2026.

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