CMS Proposes Major Medicare Compliance Relief for 2027

The Centers for Medicare & Medicaid Services just released proposed rules for 2027 that could really cut down on compliance hurdles for Medicare agents, with most changes taking effect October 1, 2026.

These proposals represent some of the most significant regulatory relief agents have seen in years, which would make things easier around Scope of Appointments, educational events, and documentation requirements.

What Could Change

Scope of Appointment (SOA) Flexibility

• The 48-hour rule would be eliminated – you'd just need to complete the SOA before discussing plan benefits, not 48 hours in advance
• You could collect SOAs at educational events

Call Recording Requirements

• Record retention drops from 10 years to 6 years

New Special Enrollment Period

• When a beneficiary's provider leaves a Medicare Advantage network, they could change plans through you directly without calling 1-800-MEDICARE first

Educational Event Changes

• The mandatory 12-hour wait between educational events and marketing events would be eliminated
• Combined with collecting SOAs at educational events, this opens up new opportunities for how you connect with clients

Disclaimer Requirements

• Disclaimers would no longer need to happen within one minute of a call – just before discussing benefits
• SHIP referral language would no longer be required

Comment Period Open

CMS is accepting public comments on these proposed rules for 60 days. Industry stakeholders can submit feedback on the proposals during this window.

View the complete proposed rule in the Federal Register

Remember, these are proposed changes and not yet final. We'll keep you updated as CMS reviews comments and moves toward final rules.