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CMS Proposes Major Medicare Compliance Changes for 2027

CMS announced a list of Medicare compliance rulings that could go into effect as early as next year. These changes could offer relief for Medicare agents and streamline business processes. We’ve compiled a list of the proposed changes, and if finalized, what they could mean for you going forward.

For agent use only. This information is subject to change.

The Centers for Medicare & Medicaid Services (CMS) has proposed a series of Medicare compliance changes, and they are among the most agent-friendly updates in years. These adjustments can help streamline processes and give agents more flexibility in supporting clients. Said changes would take effect on October 1st, 2026.

Below is a breakdown of the proposed changes and what they mean for your business.

What Could be Changing

1. Elimination of the 48-Hour SOA

  • Agents will no longer need to collect a Scope of Appointment (SOA) 48 hours in advance
  • SOAs would only need to be collected before discussing plan benefits

2. Educational Event Changes

  • Agents would have the ability to collect SOAs at educational events
  • The 12-hour gap between educational events and marketing events would be eliminated

3. Call Recording Requirements

  • Reduces call-recording storage from 10 years to 6 years

4. New Special Enrollment Period for Provider Exits

  • When a beneficiary’s provider leaves a Medicare Advantage network, the client could change plans directly through the agent, without calling 1-800-MEDICARE first

5. Disclaimer Requirements

  • Disclaimers would only be needed before discussing plan benefits, not within the first minute of a call
  • SHIP referral language would no longer be required

What This Means for Medicare Agents

These proposed changes mark a potential turning point for Medicare agents – offering compliance relief and a more streamlined approach to serving clients.

For now, these are only proposals. Agents must continue to follow all current CMS guidelines. Our team is monitoring CMS announcements and will provide an update as the ruling moves towards finalization.

You can view the complete list of proposed changes in the Federal Register.

For agent use only. This information is subject to change.

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