Scope of Appointments (SOA) are an important part of selling Medicare Advantage and Part D prescription drug plans. That said, coming up with a system – and staying on top of ever-changing regulations – can be a bit of a hassle.
In this article, we're covering everything you need to know about SOAs, including some of the easiest ways to obtain and store them.
What Is a Scope of Appointment?
A Scope of Appointment (SOA) is a document that your client must sign prior to a scheduled appointment with you where you will discuss Medicare Advantage and/or Part D prescription drug plans.
If you don't have a signed SOA, you can't talk about either of these plan types.
SOAs are designed to protect consumers by offering transparency about the sales process. They can mark which plan types they want you to talk about, giving them a bit of control over the contents of their appointment.
As an example, a beneficiary might have the opportunity to check off or initial consent to talk about the following product types:
- Medicare Advantage plans
- Part D prescription drug plans
- Medicare Supplement plans
- Dental plans
- Vision plans
- Hospital Indemnity plans
- Other health plans (they can list them)
Some SOA templates may shorten the options by simply listing:
- Medicare Advantage plans
- Part D prescription drug plans
- Medicare Supplement plans
- Ancillary products
Whatever the beneficiary checks off or initials indicates what you are allowed to discuss during your appointment.
SOA Compliance
Scope of Appointments come with a few important compliance rules.
- When do you need the SOA to be signed?
- How long are you supposed to store it?
- How long is it good for?
Let's get into it.
48-Hour SOA Rule
As you already know, CMS brought back the 48-hour rule, which means you must get a signed SOA at least 48 hours before your scheduled appointment.
The 48-hour rule was was a longstanding rule before 2018, and it is now brought back for 2024.
This 48-hour rule should be interpreted literally. For example, if an individual signs an SOA at 4:00 PM on a Tuesday, their appointment cannot take place until after 4:00 PM on Thursday.
Criticisms of the 48-Hour Rule
Only 20% of comments supported the 48-hour rule proposal from CMS, but even still, CMS decided to go forward with signing it into law.
The biggest criticism was that there's just no positive effect of making a beneficiary wait two full days, and it may even be "detrimental" to beneficiaries.
One comment stated that seniors aren't required to wait 48 hours to purchase a car, so why should they have to wait 48 hours to discuss and enroll in a health or drug plan?
CMS' response was giving beneficiaries time to consider their options and whether they really want to meet with an agent is helpful, particularly for those who are more vulnerable.
The idea is they'll talk to caregivers and others they trust for help and advice prior to their scheduled appointment.
How Long the SOA Is Valid
Scope of Appointment (SOA) forms are valid for 12 months.
Aside from having a valid SOA for your current appointment, we encourage you to have your clients sign another one at the end of their appointment. That’ll alleviate the need to wait 48 hours in the future as SOAs are valid for a full 12 months.
SOA Storage
Once you have your completed SOA, you must keep it on file for 10 years, even if you didn't end up selling anything. If you do a telephonic SOA, you must keep that audio file for 10 years as well.
We encourage you to utilize MedicareCENTER to complete your SOAs as the system will automatically store your SOA for the required 10 years – for free.
More on MedicareCENTER shortly.
SOAs and Events
A new rule is you may not distribute or collect Scope of Appointments (SOAs) at an educational event.
Efficient Collection of SOA Forms
Collecting SOAs prior to the new 48-hour rule was somewhat of a pain, but now it really does require a system.
Thankfully, MedicareCENTER makes SOA collection and storage easy.
Check out how to send and store SOAs in MedicareCENTER with this short video:
Here are the best SOA features included in MedicareCENTER, which is free:
- 48-hour tracking: It tracks the 48-hour time period and can be turned off for walk-ins and inbound calls.
- SOA overview: See how many clients have signed their SOA right from your dashboard.
- Email or text SOA features: Open your client's record in MedicareCENTER's free CRM; click on Scope of Appointments and click Send Now. You can then choose Email or Text message.
- SOA storage: If you complete your SOA within MedicareCENTER by email or text, it will autosave for 10 years.
Communicate the Importance to Clients
It doesn't hurt to let clients know what to expect when it comes to SOAs.
While the 48-hour rule was put in place to protect consumers, it's safe to say the waiting period might really annoy some who would prefer to meet right away.
Letting clients know you are committed to following the rules and regulations set by CMS can help ease any confusion or concerns.
If you have a website, consider posting a blog post or announcement about what an SOA is and the new 48-hour rule. If you have an email newsletter or the ability to send emails to your clients in bulk, consider sending the message that way.
At the end of the day, communicating about the SOA compliance rules – and how you follow those rules – can really build trust through transparency.
Scope of Appointment FAQs
What is a scope of appointment?
A Scope of Appointment (SOA) is a crucial document that ensures insurance agents have the client's explicit permission to discuss specific products or services before a scheduled meeting. Agents that plan to discuss Medicare Advantage and/or Medicare Part D prescription drug plans must have their client or prospect sign an SOA before their appointment.
How long are you required to maintain scope of appointment (SOA) documentation?
You must keep SOA forms on file for 10 years, even if the appointment didn't end in a sale. For agents that use MedicareCENTER, this system will automatically store your SOA for the required 10 years.
How long is a scope of appointment good for?
Scope of Appointment (SOA) forms are valid for 12 months.
In what settings is a scope of appointment form not required to be collected?
You do not need to collect a scope of appointment form if you will not discuss either Medicare Advantage or Part D prescription drug plans with your client.
If you do plan to discuss either or both of these plan types, the only exceptions for the 48-hour SOA rule include:
- The forty‑eight (48) hour rule does not apply for beneficiaries approaching the last four (4) days of an enrollment period, including AEP, OEP, the Initial Coverage Election Period (ICEP), and a Special Election Period (SEP).
- The second exception is for walk‑in in‑person meetings that are unscheduled and are initiated by the beneficiary. This applies to beneficiaries who walk into an agent’s office, a kiosk, a plan’s office, or any other walk‑in location.
When must the scope of appointment be obtained for an in-person or telephonic sales presentation?
Agents must obtain a scope of appointment no less than 48 hours prior to presenting and enrolling a beneficiary into a plan. There are two exceptions to the 48 hour rule; the 48 hour rule is waived if a beneficiary is in the last 4 days of their valid enrollment period or if they are an in-person walk-in appointment.
Conclusion
There you have it – everything you need to know about the infamous Scope of Appointment form.
The new 48-hour rule from CMS might have stirred the pot a bit, but we're big fans of embracing change. Plus, MedicareCENTER makes SOA collection a cakewalk, so there's really nothing to worry about.
Don't underestimate the importance of keeping clients in the loop, and let us know in the comments if you have any additional questions about this crucial document.
