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This guide is for training purposes only and should be used in conjunction with current CMS guidelines and carrier-specific compliance requirements. All agents must stay up-to-date with the latest Medicare regulations and compliance standards. The examples provided are for illustrative purposes and should be adapted according to specific situations and requirements.

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Category: Compliant Medicare Sales Calls

Last Updated: March 12, 2025

CMS Reference: 42 CFR § 422.2260 - § 422.2274 & § 423.2260 - § 423.2276

Overview

The Scope of Appointment (SOA) is a critical step in a compliant Medicare sales call. It ensures that beneficiaries voluntarily agree to discuss specific Medicare plans before any plan details are presented.

Since these are member-initiated inbound calls, the 48-hour advance rule does not apply. Instead, agents must obtain a verbal SOA at the beginning of the call before proceeding with plan discussions.

Key CMS Requirements for Selling Medicare Plans Over the Phone

• A verbal SOA must be obtained before discussing plan details.
• The SOA must clearly identify the types of plans being discussed (Medicare Advantage and/or Part D).
• Agents may only discuss plans listed in the SOA—if a beneficiary wants to discuss a different plan, a new SOA must be obtained.
• The SOA must be captured before plan details are provided and cannot be retroactively added to the call.

How to Obtain a Compliant Verbal SOA

1. Initiate the SOA immediately after greeting the caller.
2. Read the SOA script verbatim to ensure CMS compliance.