THEI

Compliance & Regulatory Resources

Medicare marketing and enrollment must follow CMS and carrier requirements. Use the official compliance portal for the most up-to-date guidance, approved scripts, bulletins, and policies.

NEW — SOA Rule Change · Effective October 1, 2026

CY2027 Final Rule

The mandatory 48-hour waiting period between obtaining a Scope of Appointment (SOA) and conducting a personal marketing appointment has been eliminated.

Beginning October 1, 2026 for Plan Year 2027 enrollments, appointments may occur the same day an SOA is completed. All other SOA requirements remain in effect.

What Changed

48-hour waiting period eliminated. Same-day appointments permitted starting Oct 1, 2026 for PY27 enrollments.

What Stayed the Same

SOA still required before every personal marketing appointment. New SOA needed when product scope changes.

Electronic Signatures

CMS explicitly confirms electronic signatures and audio/video recordings satisfy the written requirement.

SOA Validity

SOAs remain valid for 12 months. If product scope does not change, a new SOA is not required solely because the plan year changes.

Agent Action Items
  • Obtain and document an SOA before every personal marketing appointment
  • Only discuss products identified within the documented SOA
  • Obtain a new SOA before expanding discussions to additional product lines
  • Retain SOA documentation per CMS record retention requirements
Source

CMS CY2027 Final Rule — 42 CFR §§ 422.2264(c)(3) and 423.2264(c)(3). Bulletin issued via YourFMO. For licensed agent use only — do not distribute to clients.

Official Compliance Portal

Always Current

To ensure you are using the most current CMS and carrier-approved materials, reference the official YourFMO Compliance Center.

Best Practice

Bookmark the Compliance Center and review updates regularly, especially before and during AEP/OEP.

Quick Compliance Checklist

These reminders help reduce risk and maintain CMS compliance. Always verify against current guidance.

CMS Marketing Guidelines

Use approved marketing materials and avoid misleading or unapproved plan representations.

Scope of Appointment (SOA)

Obtain and document SOA before every appointment. NEW Oct 1, 2026: 48-hour wait eliminated — same-day appointments now permitted for PY2027.

Sunfire: SOA & Applications

In Sunfire, generate CMS-approved SOA forms and enrollment applications. Send via text/email or complete in person.

If Sunfire is unavailable, use the carrier portal to obtain the official CMS-approved SOA and enrollment application.

Documentation & Retention

Maintain required enrollment and communication records per CMS and carrier retention policies.

AEP / OEP Reminder

High Priority

Before marketing or enrolling during AEP/OEP, review current seasonal compliance guidance to ensure all communications and enrollments meet CMS standards.

FAQs

Do I need to host my own compliance documents?

No. The official compliance portal ensures you are accessing the most current CMS and carrier-approved materials.

What if I'm unsure whether something is compliant?

Default to approved scripts and materials. When in doubt, verify against the official compliance portal before use.

Where should I obtain SOAs and enrollment applications?

Use Sunfire when available. If unavailable, access the official carrier portal for CMS-approved forms.