What You Should Know About Scope of Appointment

Senior couple signing an SOA form with their agent

Throughout each Annual Enrollment Period, Scope of Appointment (SOA) forms are a must-have before your meetings with beneficiaries. Below, I’ve broken down a few frequently asked questions about SOA forms.

Do I need to have an SOA for sales meetings that discuss plan benefits?

Absolutely. Completing a SOA is a CMS requirement for any appointment that might discuss Medicare Advantage or Prescription Drug Plans (PDPs). Prior to an appointment, the topics to be discussed are agreed upon between the agent and the beneficiary; they are documented by a signed SOA form. There are no exceptions.

Can I have the prospect complete an SOA form at the beginning of an individual sales appointment?

Per CMS guidelines, the SOA should be gathered prior to the appointment. Having the prospect sign an SOA form at the beginning of the appointment should not be a common occurrence; agents who do this may face disciplinary action. If an SOA cannot be completed prior to any meeting between an agent and beneficiary, the reason why must be documented once the SOA form is signed.

Are prospects who attend a sales seminar required to complete an SOA form?

No. Prospects who have RSVP’d are not required to fill out an SOA form. In general, sales presentations to groups of beneficiaries do not require documentation of beneficiary agreement because they are group sales events—not personal or individual events. Also, the range of products to be discussed would have been indicated on all event advertising materials. If you want to bring SOA forms to marketing events, CMS allows beneficiaries to fill them out for future appointments.

Do I have to wait 48 hours for another appointment to discuss a different Medicare Advantage product type with a prospect?

No. The 48-hour cooling off period is for discussing non-health-related products such as annuities and life insurance. However, prior to discussing a different Medicare Advantage product type during the same appointment, you must have the prospect complete a new SOA documenting his or her agreement to discussing a different product.

Do I need to have prospects complete an SOA form to discuss Medicare Supplement plans?

It’s not required for prospects to complete a Scope of Appointment form if they only want to talk about Medicare Supplement plans or other health-related lines of business. But prior to the appointment, it’s recommended that you have prospects fill out an SOA with the intent to also discuss drug coverage. This will give you the opportunity to present prescription drug plan options.

Are walk-ins to my office required to complete an SOA form?

Yes. Prospective walk-ins who do not have a preset appointment must document the SOA prior to beginning the meeting. You must notate this on the SOA.

If unexpected prospects are present for my properly solicited appointment, are they required to sign an SOA form?

Yes. If—and when—agents encounter unexpected prospect(s) who are present for a properly solicited and documented individual appointment, the additional prospect(s) must document the SOA prior to the beginning of the appointment. CMS views this as a beneficiary-initiated contact.

What If I have a canceled appointment or a no-show?

You must still have a completed Scope of Appointment on file for any meeting that might discuss MA or PDP plans, even if your prospect cancels the appointment, doesn’t show up, or the appointment doesn’t result in a sale.

Can I give SOA forms to providers to hand out in their office?

No. Providers must remain neutral in enrollment decisions and are prohibited from offering SOA forms or steering prospects toward any plan(s).

Do I need to submit completed SOA forms to CMS or my insurance agency?

If a request for a completed SOA is made by CMS, your insurance agency, or Field Marketing Organization (FMO), you have within 48 hours of the request to submit the completed SOA.

Are there storage and retention requirements for SOA forms?

Yes. You must retain and store all completed Scope of Appointment forms, including any SOA for no-show, canceled, rescheduled appointments, and those that didn’t result in an enrollment. CMS requires that you:

  • Ensure all SOA forms are made available upon request for a minimum of 10 years.
  • Ensure SOA forms are stored securely because they contain Personally Identifiable Information (PII).

Can I store Scope of Appointment forms electronically?

Yes. If you choose to store forms electronically, make sure all paper copies are disposed of compliantly. Any electronic storage system that contains SOA forms must be secure and encrypted. If you have a security breach, you must report it to your insurance agency or FMO promptly.

Medicare has neither reviewed nor endorsed this information.

Note: For the most current information, see the CMS Medicare Marketing Guidelines.



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