Frequently Asked Questions Related to New Scope of Appointment Rules

On April 6, 2026, as a part of the Contract Year (CY) 2027 final rule, CMS finalized new rules related to the Scope of Appointment (SOA) at 42 CFR §§ 422.2264(c)(3) and 423.2264(c)(3). 1 0F CMS eliminated the 48-hour waiting period required between the SOA completion and a personal marketing appointment, made a few additional SOA-associated regulation changes, and clarified various SOA policies. These new SOA rules apply to Medicare Advantage organizations (MAOs), Part D sponsors, section 1876 cost plans (all three types of entities collectively referred to as “plans”), and agents, brokers, and other third parties representing plans, and are applicable for all CY 2027 marketing and communications, beginning October 1, 2026.