SOA Scenario

Outbound call to a warm lead — no prior SOA

Agent calls a lead-form submitter and pitches an MA plan.

Training material only. Not legal, compliance, or enrollment advice. Always defer to current CMS guidance, your FMO's compliance team, and your carrier certifications. See disclaimers.

Scenario

A prospect submitted a web form requesting an MA quote. The agent calls the prospect back the same day and begins reviewing MA plan benefits and comparing carriers over the phone. No SOA is collected before the marketing content is discussed.

Evaluate the agent's conduct

CompliantAn SOA was required and obtained correctly.Technical violationSOA rule triggered; procedure was flawed (timing, scope, retention).Clear violationSOA was required and skipped, or the discussion exceeded the documented scope.SOA not requiredThe conversation did not trigger the SOA requirement.

On this scenario: 0/0 correct — no attempts yet.

Sources

Reviewed Jul 15, 2026 · GoAEP editorial

42 CFR §422.2264(c)
Scope of Appointment documentation before a marketing appointment.
42 CFR §422.2264
Unsolicited contact prohibition and permitted marketing activities.
CMS TPMO Rule — Call Recording
Third-Party Marketing Organization requirements including call recording and 10-year retention.

Not marketing material. Not for consumer distribution. CMS rules evolve — verify against current guidance before use.

Educational drill only. Rules and CMS guidance evolve — always defer to current CMS publications, your FMO compliance team, and your carrier certifications.