A Medicare Sales Call Review Checklist for Agencies
CMS shortened Medicare call-recording retention and moved the required disclaimer earlier in the call for 2027. Here's a current call review checklist and what to automate versus what still needs a human sign-off.
Every recorded Medicare sales call is a compliance record first and a coaching opportunity second. For contract year 2027, CMS shortened how long agencies must keep marketing and sales call recordings and moved the required disclaimer earlier in the call — which means the checklist your team was trained on last AEP is probably out of date. Below is a current call review checklist, the rules behind each line, and what to automate versus what still needs a human to sign off. What changed for CY2027 CMS's final rule for contract year 2027 (effective for marketing materials and activity starting October 1, 2026) made two changes that affect every recorded sales call: Retention is shorter. Medicare marketing and sales call recordings now have to be kept for six years , down from ten. Audio is required for the first three years; for years four through six, a complete and accurate transcript can stand in for the recording. See CMS's CY2027 marketing guideline changes . The disclaimer moved earlier. The required Third-Party Marketing Organization (TPMO) disclaimer — the line that tells the beneficiary the agent doesn't represent every plan in the area — now has to be given before any plan benefits are discussed , rather than CMS's older rule of "within the first minute" of the call ( same CMS guideline ). Everything else agencies were already graded on is unchanged. CMS still bars plans and agents from making unsolicited calls to prospective enrollees , including calls about unrelated business used to generate Medicare leads, and door-to-door solicitation. A Scope of Appointment (SOA) is still required before a one-on-one marketing appointment of any kind — in person, by phone, or by video — and the conversation is limited to the product types the beneficiary agreed to in advance; bringing up a product that wasn't on the original SOA requires documenting a second one before the agent can continue (same CMS source). One SOA rule did go away for 2027: the 48-hour advance-notice requirement. We covered that change in detail in The 48-Hour Scope of Appointment Rule Is Gone for 2027 , and what still belongs in the file in Scope of Appointment Record Keeping for the 2027 AEP . The call review checklist Use this for every recorded Medicare sales, marketing, or enrollment call — whether a manager is spot-checking a sample or reviewing one flagged by a complaint. It is not a sales script review; it is the compliance floor a call has to clear before you look at anything else. Call type is correctly identified. Confirm it is actually a Medicare sales, marketing, or enrollment call (not a service call to an existing member, which falls outside this rubric) before grading it against these items. Recording covers the entire call. No gap between the greeting and the close, including any hold or warm transfer. A recording that only starts once the "sales part" begins is a finding, not a technicality. TPMO disclaimer delivered verbatim, before benefits are discussed. Not paraphrased, and not after the agent has already walked through plan details. No sign of unsolicited contact. The call is a return call, a response to a specific request, or contact with an existing enrollee — not a cold call, a referral treated as open permission, or Medicare leads generated from an unrelated business call. Scope of Appointment on file and respected. The products discussed match what the beneficiary agreed to in advance. If the conversation drifts to a product type that wasn't on the original SOA, a second SOA should exist for it. No non-health products in a health-plan appointment. Annuities and life insurance don't belong in a Medicare Advantage or Part D appointment unless a separate appointment and scope cover them. Language stays factual. No "best," "most," "free," or other superlative/absolute claims about a plan that the plan documents don't support. The recording and any transcript are filed with a retention clock. Audio for years one through three, audio or transcript for years four through six, and the beneficiary's identity and the call date are both captured so the record is retrievable later. A call that fails item 2, 3, 4, or 5 should be treated as a critical finding — the kind that gets escalated the same day, not batched into a monthly report. Where AI call review helps, and where it doesn't get the final word Reviewing every recorded call by hand doesn't scale past a handful of agents, which is exactly why this checklist tends to get skipped once an agency grows. AgencyView's call recording and coaching connects to the agency's RingCentral account, pulls recordings onto the client record, and transcribes them automatically. Each transcript can then be scored against a rubric a manager builds and edits in the app — the same checklist above can become the actual scorecard, item by item, rather than living in a spreadsheet nobody opens. Two design choices matter more than the automation itself: Certain items can auto-fail a call. A scorecard can mark an item — like the missing TPMO disclaimer — as an automatic failure, the same way CMS treats it, rather than letting a strong overall score bury a critical miss. A high score doesn't mean a call ships untouched. When the system isn't confident about a critical item — the evidence in the transcript is ambiguous, or a required line simply doesn't appear — that call routes to a human reviewer instead of being auto-approved. Clearing the numeric thresholds is not the same as being approved; a manager still decides what gets acted on. In practice that means a manager's coaching dashboard shows scored calls, trends by agent over time, and a review queue of the calls the system wasn't sure about — not a black box that silently passes or fails people. That queue is the part worth watching closely during AEP, when call volume is highest and the cost of missing a real finding is highest too. Building this into a weekly habit A checklist only works if someone runs it on a schedule. For a small agency: Score 100% of calls automatically if volume allows it; otherwise sample at least 10% per agent per week, weighted toward new agents and anyone flagged in the last review. Review the auto-fail and low-confidence queue daily during AEP, weekly the rest of the year. Keep a short written note on every critical finding — what failed, what the agent was told, and whether a follow-up call or client outreach was needed. That note is itself part of the record CMS expects an agency to be able to produce. Re-read your own compliance notes and scripts at the start of each plan year. Rules move every contract year, and a line that was accurate last AEP, like the old 48-hour SOA window, can be gone by this one. FAQ Do Medicare sales calls have to be recorded? Yes. CMS requires plans and the agents working on their behalf to record sales, marketing, and enrollment calls with beneficiaries in their entirety, inbound or outbound, including the audio portion of a call conducted over video or web-conferencing software. How long do agencies have to keep Medicare call recordings now? Six years for contract year 2027 and after, down from the previous ten-year requirement. Audio is required for years one through three; a complete and accurate transcript can stand in for years four through six. See the CMS CY2027 guideline changes . When does the TPMO disclaimer have to be read now? Before any plan benefits are discussed, rather than the older "within the first minute" standard. Is the 48-hour Scope of Appointment rule still in effect? No — CMS removed the 48-hour advance-notice requirement for 2027. An SOA is still required before a one-on-one marketing appointment, and the conversation is still limited to what the beneficiary agreed to in advance. See our full breakdown . Can an AI tool score a Medicare sales call for compliance on its own? It can transcribe the call and grade it against a rubric, and flag the items it's confident about. It should not be the…
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