MAJOR CHANGE: Understanding the 2024 CMS Final Rule’s New 48-Hour Scope of Appointment (SOA) Rules

So it is rare that another blog compares to when it comes to quality and comprehensive content, but just did a FANTASTIC piece on the CMS final rule. And I love it.

Here is a snippet:

Understanding The New SOA 48-Hour Rule With Puja J. Amin

As we discussed previously, the 2024 CMS Final Rule included a major change to Scope of Appointment (SOA) rules. As Medicare organizations know, the Scope of Appointment is a form that beneficiaries must sign to outline the topics that are allowed to be discussed during a scheduled meeting. This helps ensure that the beneficiary stays in control, helps them make informed decisions about their benefits, and can prevent misleading marketing tactics.

The SOA changes could mean huge changes for how Medicare organizations handle outreach about their plans. So, Drips sat down with our legal counsel and outreach compliance expert Puja J. Amin from Troutman Amin, LLP. In this conversation, Puja shares key insights into the important aspects of the new rule and how companies can adapt to the change.

But first, let’s go over the details of the new 48-hour rule for Medicare Scope of Appointment forms.

How The 2024 CMS Final Rule Changes SOA

With the 2024 CMS Final Rule, there must be a 48-hour waiting period between the signing of the SOA form and the meeting or call with the beneficiary. As we already mentioned, this gives the beneficiary time to make informed choices and consult with family or trusted third parties about their coverage options.

When The 48-Hour Rule Applies

The 48-hour rule applies to all SOA forms starting September 30, 2023. It is required any time an insurance agent or broker wants to meet with a current or prospective Medicare health plan beneficiary to discuss plans and benefits.

There are two exceptions to this rule. The first exception is during the last four days of an election period, when you can obtain a same-day scope of appointment. The second exception is for “walk-in” meetings initiated by the beneficiary.


Quote from Puja J. Amin about the SOA 48-hour rule. "You have to tread very carefully here. You have to understand why this rule was implemented."

How The 48-Hour Rule Challenges The Medicare Industry

While the effects of the 48-hour rule are still unfolding, it’s already clear that it could pose challenges for Medicare outreach. In particular, the 48-hour waiting period is sure to result in some potential beneficiaries failing to follow up and complete enrollment.

Read more RIGHT NOW at:


Leave a Reply