Scope of Appointment rules for 2027: the 48-hour rule is gone

The Contract Year 2027 Medicare Advantage and Part D final rule (CMS-4212-F) relaxed several marketing rules. CMS says the changes apply to all CY2027 marketing and communications beginning October 1, 2026. The changes that matter most to agents:

• Personal marketing appointments can be scheduled any time after a Scope of Appointment is completed. The old 48-hour waiting period, and its exceptions for walk-ins, inbound calls and the last four days of an election period, no longer apply.
• SOA forms can be collected at educational events.
• A marketing event can be held directly after an educational event in the same location, as long as attendees are told and given the chance to leave.
• The Third-Party Marketing Organization (TPMO) disclaimer must be given verbally before benefits are discussed, rather than within the first minute of a call, and State Health Insurance Assistance Programs (SHIPs) are no longer listed in it.
• Sales and marketing call recordings must be kept for 6 years instead of 10, and transcripts may replace recordings for years 4 through 6.

• You still need a completed SOA before a personal marketing appointment about Medicare Advantage or Part D plans.
• The SOA still documents which product types the beneficiary agreed to discuss. If the conversation moves to a product type that is not on the SOA, complete a new SOA before discussing it.
• The SOA is still not an enrollment and does not obligate the beneficiary to anything.
• You still need to keep SOA records according to your carriers’ and FMO’s recordkeeping policies.

1. Send the SOA electronically, or collect it at an educational event, and confirm it is fully completed with the product types selected.
2. Hold the appointment whenever the beneficiary is ready. With a completed SOA there is no minimum wait.
3. Give the TPMO disclaimer verbally before you discuss any benefits.
4. Discuss only the product types on the SOA. If the beneficiary asks about something else, complete a new SOA first.
5. Store the completed SOA and any call recording where you can retrieve them, following your carriers’ and FMO’s retention policies and the new 6-year minimum for call recordings.

QuoteDeck sends Scope of Appointment forms with the rest of your client forms, stores each completed SOA with its submission time and a tamper-evident record, and keeps it on the client’s record next to their quotes, so you can move from signed SOA to appointment without switching tools.