What a TPMO is
CMS defines TPMOs broadly. It covers independent agents and brokers, field marketing organizations, call centers, and lead generators. All are paid to do marketing, sales, or enrollment work for a plan. The plan sponsor must oversee them. For contract year 2027, the rules apply to marketing that begins October 1, 2026, including a standard disclaimer said before any benefits discussion.
Marketing and sales calls must be recorded and kept for at least 6 years. Years 1 to 3 must be audio, and years 4 to 6 can be audio or a full transcript. TPMOs cannot cold call, robocall, text, or leave unsolicited voicemails. Sharing a beneficiary's data with another TPMO requires prior express written consent naming each recipient.
Rivvi is a HIPAA-compliant AI workspace with an action layer for calls, texts, and web chat. It has run AEP outreach for community pharmacies, capturing the Scope of Appointment before any plan discussion. A TPMO still owns its compliance program: the disclaimer script, recording retention, and consent records. Rivvi logs each outcome and pushes it to a connected CRM.