The CMS CY 2027 Final Rule includes updates to call recording, TPMO disclosures, Scope of Appointment (SOA) requirements, educational events, and Special Enrollment Periods (SEPs). According to the guide, the updated rules take effect October 1, 2026. Sales activities involving 2026 plans remain subject to the 2026 plan year requirements.
Key Changes
Simplified Call Recording Rules
All marketing, sales, and enrollment calls must still be recorded in their entirety. Marketing and sales call retention has been reduced to six years, with audio retained for the first three years and transcripts retained for the next three years. Enrollment recordings still require 10-year retention.
Clearer TPMO Rules
TPMO disclaimers are still required, but only before plan benefits are discussed.
Faster, More Responsive Conversations
The 48-hour waiting period after completing a Scope of Appointment (SOA) has been removed. Agents may discuss plans immediately after completing an SOA, including during the same day, call, or meeting.
More Flexible Events
Educational and sales or marketing events may occur on the same day. The prior 12-hour buffer requirement has been eliminated. The guide states that agents should clearly communicate when education ends and sales activities begin and provide consumers an opportunity to leave before sales discussions start.
Special Enrollment Periods (SEPs)
Some SEPs now require CMS validation, and certain enrollments must be completed through Medicare.gov or 1-800-MEDICARE. The guide notes that agents continue to play a key role in assisting beneficiaries throughout the process.
What Did Not Change
The guide states that SOAs are still required, misleading or deceptive marketing remains prohibited, TCPA rules still apply, and consumers must always have the option to decline, pause, or leave a conversation.
Bottom Line
According to the guide, CMS removed unnecessary barriers while expecting professional judgment, clear communication, and strong documentation.