If you sell Medicare Advantage or Part D plans, you know how much work can go into getting an appointment on the calendar. Your client is available, you’re available, and maybe their adult daughter has rearranged her schedule to join the conversation.
Having to delay that discussion because of a waiting period could be frustrating for everyone involved. This AEP, agents have more flexibility.
According to CMS’s 2027 final rule, published April 6, the agency eliminated the requirement to wait 48 hours between completing a Scope of Appointment form and conducting a personal marketing appointment.
The marketing changes apply to discussions about 2027 coverage beginning October 1, 2026. That means this change already applies during the current Annual Election Period.
For agents trying to help as many clients as possible, the ability to complete an SOA and then have the conversation that same day can make scheduling significantly easier.
Of course, removing the waiting period doesn’t eliminate the Scope of Appointment itself.
Under the current federal regulations, agents must still agree upon and document the scope before the personal marketing appointment. For in-person appointments, the SOA must be in writing.
This is the agreement about which types of products you’ll discuss. If the client agreed to talk about standalone Part D coverage, that doesn’t automatically authorize a presentation about every other product you sell.
CMS also makes clear that the requirement applies when clients initiate contact, including unscheduled calls and walk-ins, if the conversation becomes a personal marketing appointment. “They called me” isn’t a reason to skip the Scope of Appointment.
Suppose you’re meeting with a client about Part D coverage, and they ask about Medicare Advantage. If Medicare Advantage wasn’t included in the agreed scope, you still need a separate SOA covering that additional discussion.
The good news is that completing the additional SOA no longer starts another 48-hour waiting period. You can document the expanded scope and continue helping the client.
Take a look at your appointment reminders, scheduling instructions, and office procedures. If they still tell clients they must wait two days after completing an SOA, it’s time for an update. Make sure anyone helping schedule your appointments understands the change and follows your carriers’ current procedures.
And remember that some clients will still want time to think or involve a family member. Give them that time.
Use the added flexibility to make appointments more convenient and spend the conversation where it matters: helping clients understand their options and choose coverage that fits their needs.