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Scope of Appointment (SOA): Rules, Timing & Requirements

Reviewed against CMS guidance · Northgale Compliance Research · 2026-08-31

The short version: a Scope of Appointment documents what a beneficiary agreed to discuss before a marketing appointment. It must be completed before the appointment — the 48-hour waiting period was eliminated in the CY2027 Final Rule — and it must cover only the products the beneficiary agreed to discuss.

What an SOA must contain

The SOA records the beneficiary's agreement to discuss specific plan types (Medicare Advantage, Part D, or both), the appointment, and the scope of the discussion. Presenting plans outside the SOA's scope is a compliance violation.

The CY2027 change: the 48-hour rule is gone

CMS eliminated the 48-hour waiting period between documenting the SOA and the appointment. The requirement that matters now is documentation before the appointment — a records question, not a timing question.

SOA and call recording by state

Call recording is a federal CMS requirement — but who must consent to the recording is state law. See our state-by-state guide for your state's one-party vs. all-party consent rule.

How Aegis helps

Aegis captures the SOA, links the call recording, and folds both into the client's compliance-defense score — so the trail exists before the audit.

Build your audit trail at the moment of sale

Aegis scores every client file 0–100 on CMS defensibility and links the SOA, recording, and disclosures — so the evidence exists before the audit.

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