Medicare scope of appointment rules
The Medicare SOA rules 2025 are put in place by CMS. The SOA (scope of appointment) is a form clients/potential clients as well as agents must complete before meeting to discuss Medicare plans. The SOA is mandatory when discussing either Medicare Advantage or PDP plans. It is always a good idea to collect a SOA before client meetings to protect both agents and clients.
Watch a quick video on the scope of appointment rules for 2024
Verbal scope of appointment
During the pandemic, agents did not host in-person meetings to discuss coverage options. At that time, many appointments took place over the phone. That led to the use of recorded, verbal SOAs.
Watch a video on Connecture & Sunfire updates for 2025
Both Connecture and Sunfire offer easy ways to collect client intake forms and include SOAs.
View the RetireFlo intake demo for Connecture
Take a look at the BlazeSync intake form on Sunfire
SOA information
- If the client calls the agent (inbound call), the 48-hour rule does not apply.
- The scope is good for 12 months from the date it is signed. You must complete the appointment within that time or obtain a new scope. The scope is still good if the call drops and the same agent calls the client back.
- If additional benefits are added to the discussion, a new scope is necessary.
How long is an SOA good
A scope of appointment is good for 12 months from the signature date. During the appointment, it is important to discuss only products that were agreed to and included in the scope. If additional products are added, the beneficiary needs to sign a new scope.
If the client needs to sign a new SOA, this restarts the 48-hour waiting period and may move your meeting date further out. This rule applies to any product regulated by CMS.
Click here for a generic SOA
CMS guidelines
In order to be complaint with CMS, agents need to have their clients complete a SOA form. The CMS final rule went into effect September 30. 2023 and added changes to how agents collect an SOA.
The SOA rules apply to agents and brokers who discuss Medicare coverage options and plans. The 48-hour rule was put in place so beneficiaries could avoid the high-pressure sales tactics some agents use. The 48-hour period provides beneficiaries time to consult friends, relatives or anyone they like to research their options. This time also provides agents time to prepare for the discussion.
Agents are able to contact the beneficiary once the SOA is completed for up to 12 months. It is essentially permission to contact until the meeting takes place. The beneficiary has the option to opt out annually.
Please note, if the beneficiary does not select a coverage option on the SOA, Medicare requires the agent to avoid discussing that option without a new SOA where the option is clearly selected.
Exceptions to the 48-hour rule
If the beneficiary is in the last four days of a valid election period, agents may collect a same-day SOA.
When the beneficiary walks into your office and initiates a conversation about coverage options, agents can take a same-day SOA. This same rule applies to inbound call initiated by the beneficiary to the agent requesting advice.
How long do you need to keep a SOA
Agents must be able to access the SOA form for ten years. Clients have the right to request a copy anytime within that time frame without any issues. The SOA can provide help in the event that an issue or dispute occurs. The Scope is in place to protect the consumer, but it can also protect the agent.