The Scope of Appointment is the compliance form that protects you and the client. Get the timing or recordkeeping wrong and you risk a CTM complaint — or worse. Here are the 2026 rules.
The old 48-hour advance-SOA requirement is eliminated effective October 1, 2026 under the CY2027 final rule (Federal Register, 91 FR 17384) — it still applies through September 30, 2026. From October 1, 2026 you no longer wait 48 hours — but the SOA must still be documented and agreed before the personal marketing appointment begins (in writing for in-person appointments). The SOA must specify which product types you'll discuss — and you can't stray outside that scope.
Beneficiary name and contact, the product types agreed to (MA, PDP, Medigap, etc.), the date, the agent's information, and the beneficiary's agreement. Electronic SOAs are allowed if they capture the same elements and a verifiable agreement.
CMS requires agents and plans to retain SOA records for 10 years (42 CFR §423.505) — far longer than most agents expect. Call recordings now follow a split rule under the CY2027 final rule (Federal Register, 91 FR 17384, effective June 1, 2026): the marketing/sales portion must be kept 6 years (audio for years 1–3; audio or a complete transcript for years 4–6), while the enrollment portion stays 10 years. A lost record from years ago can still surface in an audit — store everything systematically with the retention date logged.
Most Complaint Tracking Module (CTM) complaints trace back to scope or documentation gaps. A simple SOA + compliance log that flags a late SOA (one dated after the appointment) and tracks the split retention dates (6 years sales/marketing, 10 years enrollment, per 91 FR 17384) keeps you audit-ready and protects your contract.
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Not yet — the CY2027 final rule (91 FR 17384) eliminates the 48-hour advance requirement effective October 1, 2026; it still applies through September 30, 2026. The Scope of Appointment must still be documented and agreed before the marketing appointment begins (in writing for in-person), but from October 1, 2026 there is no longer a 48-hour wait.
CMS requires Scope of Appointment records to be retained for 10 years. Call recordings follow a split rule under the CY2027 final rule (91 FR 17384, effective June 1, 2026): the marketing/sales portion is kept 6 years and the enrollment portion 10 years.
Skipping or mis-scoping an SOA is a common trigger for CTM complaints and can lead to carrier or CMS disciplinary action. Always document scope before the appointment.
Figures on this page are verified against U.S. government primary sources: