What changes for you on October 1

CMS finalized the CY2027 Medicare Advantage and Part D rule on April 2, and the marketing provisions take effect October 1, 2026. Two changes directly affect how you schedule appointments and run events — here's what's different.

The 48-hour Scope of Appointment wait is gone

Previously, CMS required a 48-hour gap between when a beneficiary signed a Scope of Appointment (SOA) and when you could hold a personal marketing appointment with them. That waiting period is eliminated as of October 1.

The SOA itself is still required for every personal marketing appointment — that hasn't changed. What's changed is timing: you can now collect the SOA at the start of the appointment, on the same call, or at the same event as the appointment itself. There's no longer a mandatory gap between the two.

The 12-hour educational/marketing event gap is eliminated

CMS previously required a 12-hour separation between an educational event and a marketing event held at the same venue. That requirement is also gone. In addition, SOA collection at educational events — previously not permitted — is now allowed.

What this means for you

In practice, these changes give you more flexibility to combine education and enrollment activity into fewer touchpoints with a beneficiary, without the scheduling gaps the old rules required. As always, every marketing activity still needs to follow Imperial's compliance guidelines and CMS's remaining marketing requirements — if you're not sure how a specific scenario is affected, check with your Broker Relations representative before the change takes effect.