2024 CMS Final Rule: What You Need to Know

April 26, 2023

Listen in on a conversation between our President (Mike Smith) and Executive Vice President (Josh Slattery) as they discuss the 2024 Medicare Marketing Final Rule.

Key Takeaways:

Educational Events

  • Sales events cannot occur within 12 hours of an educational event at the same location.
  • Agents can not collect SOAs at educational events but lead cards are still allowed

Business Reply Cards (BRCs)

  • No door-to-door solicitation with a BRC or SOA
  • 12-month permission-to-contact (PTC) on BRC and SOA

Prohibiting marketing benefits in a service area where those benefits are not available

  • Unless unavoidable because of local or regional media that covers the service area


  • TPMOs to list or mention all MA sponsors they represent on marketing materials
  • TPMO disclaimer must now mention the number of organizations and plans represented
  • Placing discrete limits around the use of the Medicare name, logo, and Medicare Card

Clarifying the requirement to record calls between TPMOs & beneficiaries

  • It’s now clear the requirements include virtual connections, video conferencing, and any telepresence methods

Scope-of-Appointment (SOA)

  • Requiring 48 hours between an SOA and an agent meeting with a beneficiary
  • Exceptions for beneficiary-initiated walk-ins and four days prior to a valid enrollment period

CMS is not addressing its proposal to prohibit TPMOs from distributing beneficiary contact information in this final rule and may address it in a future final rule.

Thanks for listening! Questions? Call our Medicare team and we’ll be here to help!

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