October 15 arrives faster than you think. One missed Scope of Appointment (SOA), an unclear disclaimer, or a skipped consent can derail your AEP season before it starts.
This is your last-mile compliance checklist—the final prep that turns crunch time into a smooth, documented, and audit-ready process. Inside, you’ll see how to lock in SOAs, nail your disclaimers, streamline call recording consent, and fine-tune appointment rules so your outreach runs without a hitch.
Think of it as your preflight checklist for AEP and OEP. Built for speed. Tuned for accuracy. Designed for complete compliance. Let’s get the details in place now so you can start day one ready to go.
Agents and brokers must agree on and record an SOA at least 48 hours before a scheduled personal marketing appointment. Two exceptions apply:
Walk-ins initiated by the beneficiary.
SOAs completed during the last four days of a valid election period.
An SOA is more than a form...it defines what you can discuss during the meeting. If the conversation shifts beyond the original scope, you must capture a new SOA before moving forward. The safest approach: standardize intake and use electronic SOAs for accurate time stamps and secure storage. This eliminates guessing, speeds up audits, and keeps you aligned with CMS training and plan requirements.
Checklist:
Require SOA completion before booking appointments. Block calendars if under the 48-hour threshold unless an exception applies.
Store SOAs with version dates, agent ID, and beneficiary ID.
Re-issue SOAs if new products are discussed.
Train producers on the two exceptions.
If you market for more than one MA or Part D organization, you’re a Third-Party Marketing Organization (TPMO). You must present the standardized TPMO disclaimer:
In the first minute of any sales call.
On your website, in emails, in chat, and on marketing materials.
Prominently in print and TV ads.
If you truly represent every plan in the service area, CMS offers an alternate disclaimer.
Starting October 1, 2024, TPMOs must obtain prior express written consent to share a beneficiary’s personal data with another TPMO. The consent must be one-to-one for each recipient—this applies even to entities under the same parent company.
Personal beneficiary data collected by a TPMO for MA or Part D marketing or enrollment can only be shared with another TPMO with prior express written consent.
Consent must be one-to-one for each recipient. This policy was finalized for CY 2025 and remains in effect. Build it into your lead forms and vendor contracts
Checklist:
Place the TPMO disclaimer in a global website header or persistent banner.
Add a “first-minute” line to call scripts.
Update ad and landing page templates with the disclaimer.
Add one-to-one consent fields to all lead forms. Reference the rule in your insertion orders with vendors.
TPMOs must record all marketing, sales, and enrollment calls in full—including web-based audio—and keep them for ten years if related to sales or enrollment.
Announce recording at the start of the call and secure a verbal “yes.”
Some states require all-party consent—use a universal script to avoid mistakes.
Store recordings in secure, searchable archives with role-based access.
Checklist:
Add consent language to the top of scripts.
Record and tag every marketing, sales, and enrollment call.
Retain recordings for ten years.
Map recordings to client and opportunity records.
With Quotit, starting inbound or outbound calls is effortless. Our platform instantly identifies the caller, pulls up their complete client record in our built-in CRM, and automatically attaches the call recording to their profile for future reference.
Missed a call? No problem. Quotit’s call recording tool logs it, stores it securely, and keeps every interaction tied to the right client record. You get a full, auditable history—organized, accessible, and compliance-ready.
Cold calling Medicare prospects.
Door-to-door visits without a prior appointment.
Approaching beneficiaries in public spaces.
Email is allowed only if it includes a clear opt-out.
Follow-up contact is fine when the beneficiary initiates it or gives permission. Document the lead source and store proof of consent in your CRM.
Email is fine if each message includes a clear opt-out.
Plans may contact current members about plan business with proper notices
Checklist:
Require a lead source field and attach consent proof.
Include unsubscribe links in all emails.
Configure dialers to block Medicare cold call attempts.
Capture SOAs at events and follow the 48-hour rule for scheduling.
Step 1: Data triage
Pull all Medicare clients by carrier and plan type.
Flag recent movers, 2025 switchers, and anyone who used a SEP.
Step 2: Timed outreach
Days 1–2 after ANOC delivery:
Text and email: “Your plan mailed your 2026 update. I will review your changes and share options.”
Keep language factual and free of superlatives.
Days 3–7:
Call and leave a brief voicemail: “I reviewed your ANOC letter. We should book a quick call to talk through your 2026 changes and see if a switch helps.”
Days 8–14:
Follow-up text and email with a booking link and two time options.
Step 3: Calendar hygiene
Let clients self-book.
Send a confirmation the day before and one hour before the meeting.
Premium increase
Script: “Your premium goes up in 2026. Let’s check a lower-cost option that keeps your doctors and drugs.”
Formulary change
Script: “One of your medications is changing coverage in 2026. I will compare plans that keep it covered to avoid disruption.”
Network shift
Script: “Your doctor or pharmacy shows a 2026 network change. I can verify providers or look at a plan that fits your care team.”
Confirm SEP eligibility if needed and document the rationale.
Keep a written summary of every recommendation.
Map all notes, SOAs, and recordings to the client record.
Scenarios
Premium up, benefits stable
Offer like-for-like alternatives. Show total annual cost.
Formulary exclusion
Run a drug comparison across plans. Document the client’s final choice and preferred pharmacy.
Provider dropped
Verify in-network options or pivot to a plan that includes the preferred PCP or specialist.
Outbound ANOC contacts sent
Meetings booked per 50 contacts
Kept-appointment rate
Plan switches completed
Retention rate for current clients
Review weekly from September 30 through AEP launch. Use your CRM dashboards to spot bottlenecks and adjust cadence.
Built-In Templates
eSOA templates with time stamps and secure storage.
Call recording and storage directly in the contact.
Appointment confirmations with compliant language.
Consent and lead source documentation.
Built-In Speed
Everything lives where your team already works—less time searching, more time serving clients.
Compliance is the track that lets you run fast without derailing. Lock your SOAs, fix your disclaimers, record the right calls, and keep proof in reach. Start October ready and let Quotit carry the paperwork while you carry the conversation.
Compliance-ready and confident.
October 15th lands clean.
Templates that save the day.
Your best season starts here.
This document is intended for internal use by licensed agents affiliated with Allstate. CMS marketing regulations, including the prohibition on plan-specific marketing prior to October 1, apply only to communications directed at Medicare beneficiaries. If any portion of this document is used externally or shared with clients, agents must ensure that such communications are strictly educational in nature and fully compliant with CMS guidelines.