Seven ways CMS simplified Medicare marketing for 2027

CMS made key adjustments in their 2027 Final Rule that will make most independent Medicare agents quite happy. These changes took effect June 1, 2026 for 2027 Medicare plan marketing, which may begin October 1, 2026.

The changes remove barriers in the sales process. Below are the seven that matter most in the field — for the full regulatory text, see the 2027 Final Rule in the Federal Register (CMS-4208-F3, published April 6, 2026).

1. No more SOA 48-hour waiting period

Gone is the pesky 48-hour waiting period after signing a Scope of Appointment (SOA) form. Agents may now provide the SOA, have the client fill it out and sign, and immediately hold the appointment. In another loosening of restrictions, agents can now also offer and collect SOAs at educational events, although no plan-specific marketing may occur during the event.

SOAs can be established electronically, via voicemail or on paper. SOAs are effective for 12 months after the date of signature or verbal agreement.

How to save the SOA in the client record.

2. Personal marketing appointments defined

CMS also clarified that a “personal marketing appointment” is for one person or small group, such as a couple, discussing their specific health coverage needs with the agent. In-person personal marketing appointments require a written SOA. At these appointments, the agent may continue to provide marketing materials, distribute and accept plan enrollment applications (post October 15), give a sales presentation, and discuss the individual personal needs of the prospective client(s).

3. Record and save those calls

Recording all marketing, sales and enrollment phone conversations in their entirety is still required via web-based technology. These recordings must be archived for six years (down from 10 years). The first three years of the six must be in audio format, after which they may be converted to a transcript. Calls that do not involve marketing, sales or enrollment do not need to be recorded.

See how Smart Agent Medicare CRM archives recordings.

4. TPMO disclaimer less awkward

Now reciting your Third Party Marketing Organization (TPMO) disclaimer simply needs to occur before discussion of plan benefits — not within the first minute of a sales call or meeting. Agents no longer need to include State Health Insurance Assistance Programs (SHIP) in their count. This timing change allows the conversation to flow more naturally.

The other rules around the TPMO disclaimer remain in place. The TPMO template is: “Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. You can always contact Medicare.gov or 1-800-MEDICARE for help with plan choices.”

5. Events can be held consecutively

Previously, agents were required to space educational and sales events apart by at least 12 hours when holding them at the same location. This 12-hour requirement has been eliminated, as many prospective enrollees wanted to learn more about their options right away. If you choose to hold back-to-back educational and sales events, you must make it clear when the educational or sales portion has ended and give sufficient time for attendees to leave between meetings.

Salesforce Scheduling Integration | Calendly

6. Language and translation services

Agents no longer need to provide the Notice of Availability that explains language assistance and auxiliary aids/services.

7. Descriptive language

CMS simplified the rules around using words such as “best” and “most” without supporting documentation, as this rule was duplicative of the general ban on misleading, confusing, or materially inaccurate content. The prohibition against misrepresenting information remains in place. A good rule of thumb is to be specific in your marketing claim — “Our agency has helped over 400 seniors find the right Medicare coverage for their needs” vs. “We’re the best and most popular Medicare broker in town!”