Medicare Scope of Appointment (SOA): Form and 2027 Rules
Where to get a Medicare Scope of Appointment form, what it must include, how long it lasts, and the 2027 rule that ended the 48-hour wait on October 1, 2026.
A Scope of Appointment (SOA) records which types of Medicare products a beneficiary agreed to discuss before a personal marketing appointment. During the appointment, an agent can discuss only those product types. An SOA is valid for 12 months from the beneficiary's signature or first request for information. For 2027 marketing, beginning October 1, 2026, CMS removed the 48-hour wait between completing the SOA and holding the appointment. The SOA still has to be agreed and recorded before the appointment starts.
The rules are in 42 CFR 422.2264(c)(3) for Medicare Advantage and 42 CFR 423.2264(c)(3) for Part D. CMS changed them in the contract year 2027 final rule, published April 6, 2026, and answered follow-up questions in a May 26, 2026 memo to plans (copy hosted by Hall Render).
Where to get a Scope of Appointment form
Start with the carrier whose plans you will discuss. Carriers provide SOA forms and instructions to the agents they appoint, and a carrier may require its own form or capture system. Check that its instructions cover the 2027 rules before you use a form saved from an earlier season.
CMS currently provides no model SOA and no SOA script, according to the 2027 final rule. Forms labeled "CMS" or "generic" come from carriers, FMOs, or vendors working from the regulation.
The same rule treats several things as SOAs when they name the product types to be discussed: business reply cards, voicemails, online forms, and other requests for information. A web form that asks an agent to call about Medicare Advantage plans can serve as the SOA for that call.
What the SOA needs to show
| Item | Status | Source |
|---|---|---|
| Type of products to be discussed, such as MA, MA-PD, or standalone Part D | Required | 2027 final rule |
| Written record for an in-person appointment; an electronic signature counts | Required | 42 CFR 422.2264(c)(3)(i), CMS memo |
| Audio or video recording, or an electronic record, for an appointment by phone or video | Accepted | 2027 final rule |
| Appointment date and beneficiary contact information | Recommended by CMS | 2027 final rule |
| Plan year | Optional | CMS memo |
Your carrier's form may ask for more. Whether to name a plan year affects how long the form stays useful, covered below.
When an SOA is required
An SOA comes before every personal marketing appointment. The 2027 rule defines that as an appointment tailored to an individual or a small group, such as a married couple, to discuss marketing topics. A small group means people who are generally related or living in the same household, such as a parent and child who are both eligible. Unrelated people meeting together, such as a small group at a library, each need their own SOA. The appointment is not defined by location, so phone and video appointments count.
CMS also removed the word "scheduled" from the rule. When the contact is tailored to the person and is about marketing topics, an SOA is required whoever starts it: an agent's outbound call, a beneficiary's inbound call, a walk-in, a web chat, or a web form.
The rule also lets agents collect SOAs at educational events, which was previously prohibited. Marketing still cannot happen at the educational event itself. A marketing event can now directly follow one, though, without the 12-hour gap the old rule required. Attendees must be told the educational event is ending and given a chance to leave before the marketing event starts, under 42 CFR 422.2264(c)(2)(i).
Is there still a 48-hour wait?
No. The 2027 final rule eliminated the 48-hour waiting period that the April 2023 rule had added, along with its two exceptions for walk-ins and the last four days of an election period. An agent can record the SOA and hold the appointment the same day. The rule gives an example. A beneficiary with an SOA for Part D asks about Medicare Advantage partway through the appointment. The agent records a new SOA covering Medicare Advantage and can continue the conversation right away.
The change applies to all contract year 2027 marketing and communications, beginning October 1, 2026. If you are still discussing 2026 plans with someone who has another enrollment opportunity, confirm with your carrier how it applies the change.
How long is a Scope of Appointment good for?
12 months. Under 42 CFR 422.2264(c)(3)(iii), an SOA, business reply card, or other request for information is valid for 12 months after the beneficiary's signature date or the date of their first request for information.
Within those 12 months, you can use the same SOA for several phone, video, or in-person appointments, as long as the product types stay the same. CMS's memo confirms that an SOA recorded for a phone appointment also covers a later in-person appointment within the window. A beneficiary who asks not to be contacted again must be respected, even inside the 12 months.
Plan year depends on the form's wording. If the SOA names a plan year, discussing a different plan year needs a new SOA. If it names only the product type, it covers other plan years of that product type within the 12 months. SOAs covering next year's plans can be collected before October 1, as long as the marketing conversation about those plans waits until October 1.
| Situation | New SOA needed? |
|---|---|
| Follow-up call about the same product types, inside 12 months | No |
| In-person meeting after a recorded phone SOA, same product types, inside 12 months | No |
| Beneficiary asks about a product type not on the SOA | Yes, for that product type |
| SOA says "2026 plans" and you want to discuss 2027 plans | Yes |
| SOA names Medicare Advantage with no plan year, and you discuss 2027 Medicare Advantage plans on or after October 1, inside 12 months | No |
| More than 12 months since the signature or first request | Yes |
Sources: 42 CFR 422.2264(c)(3)(iii) and CMS's May 26, 2026 memo.
Keep the record where the carrier can find it
Agents and brokers must secure and document an SOA before a personal marketing appointment, and plans must keep a system for confirming that they do, under 42 CFR 422.2274(b)(3) and (c)(9)(ii). Because the plan has to confirm those records, expect your carrier to ask for them. Store each SOA the way the carrier instructs, labeled with the beneficiary, date, and product types, so it can be matched to the appointment and any enrollment that followed.
An SOA only helps if the agent holding the appointment is cleared to sell the carrier's products named on it. Before AEP, confirm each producer's license, carrier training, and appointment. The AEP dates guide has a carrier readiness worksheet, and the Medicare onboarding guide covers the full review. InsureTrek's appointment reporting shows which producers are appointed with each carrier. It does not capture or store Scope of Appointment records.