Agent & Marketing Rule Changes – Key Highlights

CMS has released updates for PY2027 that introduce several agent-friendly changes to Medicare sales and marketing requirements. Below is a summary of the most impactful updates:

Timing of Sales Appointments After SOA Completion

Agents are no longer required to wait 48 hours before conducting a sales appointment after a Scope of Appointment (SOA) is completed. Appointments may now occur immediately following SOA completion.

Additional Requirements:

  • Spouses/family members may sign the same SOA
  • In-person appointments require a written SOA
  • Telephonic/virtual appointments may use audio, audio-visual, or electronic SOAs
  • One SOA can cover multiple appointments within the same plan year
  • A new SOA is required when discussing a different plan year

Collection of SOAs at Educational Events

Agents are now permitted to collect SOAs during educational events.

  • No sales or marketing may occur during the educational event
  • Sales activities may begin after the event concludes

Marketing Events Following Educational Events

CMS has eliminated the previous 12-hour waiting period between educational and marketing events.

  • Marketing events may now occur immediately after an educational event and in the same location
  • Agents must:
    • Clearly notify attendees that the educational event has ended
    • Inform them a marketing event will begin
    • Provide a reasonable opportunity to leave (e.g., short break)
TPMO Disclaimer Timing Update

The requirement to read the TPMO disclaimer within the first minute of a call has been removed.

  • Disclaimer must now be provided prior to discussing any plan-specific benefits
Updated TPMO Disclaimer Language

The updated disclaimer removes SHIPs and simplifies required language.

If NOT representing all plans:

“We do not offer every plan available in your area. Currently we represent [X] organizations which offer [Y] products in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options.”

If representing all plans:

“Currently we represent [X] organizations which offer [Y] products in your area. You can always contact Medicare.gov or 1-800-MEDICARE for help with plan choices.”

Applies to:

  • Sales calls
  • Websites
  • Marketing materials
  • Email signatures

Record Retention for Telephonic Sales Calls

CMS has reduced retention requirements:

  • 6 years total (previously 10 years)
  • Years 1–3: Audio recordings required
  • Years 4–6: Audio recordings or transcripts acceptable

Bottom Line

These updates represent a more flexible and agent-friendly environment, while still maintaining compliance standards. Key improvements include:

  • Faster sales timelines
  • Fewer administrative delays
  • Simplified disclosure requirements
  • Reduced record retention burden

Agents should continue to prioritize clear communication, proper documentation, and compliance adherence.