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Medicare SOA Rules: An Overview
The Medicare Scope of Appointment (SOA) rules are regulations put in place by the Centers for Medicare & Medicaid Services (CMS). These rules require both clients/potential clients and agents to complete an SOA form before meeting to discuss Medicare plans. The SOA is mandatory when discussing either Medicare Advantage or Prescription Drug Plans (PDP).
Collecting a Scope of Appointment before client meetings is always recommended as it protects both agents and clients. The SOA form serves as a formal agreement outlining which Medicare products will be discussed during the appointment, ensuring transparency and preventing unwanted sales pressure.
Verbal Scope of Appointment
During the pandemic, when in-person meetings were limited, many appointments took place over the phone. This led to the implementation of recorded, verbal SOAs as an alternative to written forms. In 2025, these verbal SOAs remain valid, provided they meet all compliance requirements including proper recording and storage.
Key SOA Requirements and Information
- 48-Hour Rule: SOA forms must be collected at least 48 hours before the appointment. However, if the client calls the agent (inbound call), this rule does not apply.
- Validity Period: The scope is valid for 12 months from the date it is signed. You must complete the appointment within that timeframe or obtain a new scope.
- Call Continuity: If a call drops and the same agent calls the client back, the original scope remains valid.
- Additional Products: If additional benefits are added to the discussion beyond what was initially agreed upon, a new scope is necessary.
It's critical to discuss only products that were agreed to and included in the scope during the appointment. If additional products are introduced, the beneficiary needs to sign a new SOA, which restarts the 48-hour waiting period and may delay your meeting date.
Exceptions to the 48-Hour Rule
While the 48-hour rule is standard, there are several important exceptions:
- 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
- For inbound calls initiated by the beneficiary to the agent requesting advice
- During the Annual Election Period (AEP), Open Enrollment (OEP), Initial Coverage Election Period (ICEP), or a Special Election Period (SEP)
SOA Retention Requirements
Agents must maintain access to SOA forms for ten years. This requirement applies to all completed SOA forms, regardless of whether a plan was sold, including no-shows and canceled appointments. For verbal SOAs conducted over phone or video calls, recordings must also be kept on file for ten years, in accordance with call recording regulations.
Clients have the right to request a copy anytime within that timeframe. The SOA serves as protection for both consumers and agents in the event of disputes or compliance checks.
Understanding the SOA Form
The Scope of Appointment is a federally required form for all new and renewal sales appointments with Medicare insurance agents. It provides potential policyholders and beneficiaries with a list of topics that may be discussed during their meeting, typically including:
- Medicare Advantage plans
- Medicare Supplement plans
- Part D prescription plans
- Other insurance products that the beneficiary may select
Only CMS-approved SOA forms can be used; agents should not create their own forms. The completed SOA should be submitted to the carrier with each Medicare Advantage Prescription Drug (MAPD) or PDP enrollment application, including applications submitted electronically.
Automating SOA Management with SOA Assist Pro
Managing the SOA process manually can be time-consuming and prone to compliance risks. SOA Assist Pro offers a comprehensive solution to automate the process of electronically sending, receiving, and tracking all SOAs sent to your clients.
With SOA Assist Pro, Medicare agents can:
- Send SOA forms via email or text message with automated tracking
- Receive instant notifications when clients complete forms
- Store all SOA documentation securely for the required 10-year period
- Access detailed reporting and compliance monitoring
- Integrate with existing agency management systems
By streamlining the SOA process, agents can focus more on serving clients and less on administrative paperwork while maintaining full compliance with CMS regulations.
In conclusion, understanding and properly implementing the Medicare SOA rules is essential for all insurance agents working with Medicare products. The 2025 rules continue to emphasize transparency and consumer protection while allowing agents to effectively serve their clients through proper documentation and compliance.