CMS Audit Readiness: 10 Things Your Call Center Needs in Place Today
A CMS audit can arrive with little warning, and the consequences of failing one range from corrective action plans to significant financial penalties—or even losing your ability to sell Medicare plans. The good news? If you have the right systems and documentation in place, an audit becomes a routine verification rather than a crisis. Here are the 10 critical items your call center needs ready today.
The 10-Point CMS Audit Checklist
1. Call Recordings
Call recordings are the backbone of CMS audit readiness. CMS requires that all sales calls resulting in Medicare enrollments be recorded and retained for a minimum of 10 years. This isn't optional—it's one of the first things auditors request.
What CMS Expects for Call Recordings
- 100% recording: Every sales call must be recorded—no exceptions, no opt-outs for agents
- 10-year retention: Recordings must be stored securely and accessible for the full retention period
- Quick retrieval: You must be able to locate and produce a specific call recording within a reasonable timeframe
- Quality standards: Recordings must be audible, complete, and include both sides of the conversation
For a deeper dive into the technical and regulatory requirements, see our guide on CMS call recording requirements.
2. Scope of Appointment (SOA) Documentation
Before discussing any specific plan details with a Medicare beneficiary, agents must have a signed Scope of Appointment form that documents which types of products the beneficiary has agreed to discuss. This protects both the beneficiary and your agency.
SOA Requirements at a Glance
The SOA must be obtained at least 48 hours before an in-person appointment (phone appointments require it before the call). It must specify the product types to be discussed, be signed by the beneficiary, and be retained for 10 years. Review the complete SOA rules and requirements to ensure your process is airtight.
Common SOA Failure Points
Auditors frequently flag SOAs that are missing signatures, have incorrect dates, list products not discussed, or were obtained after the sales conversation already started. Implement digital SOA collection with automated validation to eliminate these errors.
3. Compliance Monitoring Records
CMS expects you to actively monitor your agents for compliance—not just train them once and hope for the best. You need documented evidence that your agency conducts regular quality assurance reviews and acts on the findings.
Call Monitoring Logs
Maintain records of which calls were monitored, by whom, when, and what was found. Document both compliant and non-compliant calls.
QA Scorecards
Use standardized scorecards for evaluating calls. Track compliance-specific items: disclosures given, accurate plan information, no high-pressure tactics.
Trend Reporting
Track compliance scores over time. CMS wants to see that you identify trends and take action—not just check a box.
Supervisor Sign-Off
Document that supervisors reviewed monitoring results and signed off on findings. Show a clear chain of accountability.
4. Agent Training Records
Every agent who sells Medicare products must complete required training before they start selling—and you need proof. CMS auditors will ask for documentation of initial training, annual recertification, and any supplemental training.
Training Documentation Checklist
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AHIP certification: Current AHIP (or equivalent carrier-approved) certification for every active agent
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Carrier-specific training: Completion records for each carrier's product training modules
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Compliance training: Annual CMS compliance training with attestation and quiz scores
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Remedial training: Records of additional training provided after compliance violations or coaching sessions
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Training dates: Timestamps proving training was completed before the agent began selling
5. Marketing Material Approvals
Every piece of marketing material used to promote Medicare plans—whether it's a flyer, email, landing page, social media post, or call script—must be approved by CMS or the relevant carrier before use. Using unapproved materials is one of the most common audit findings.
High-Risk Area
Unapproved marketing materials are one of the most frequently cited violations in CMS audits. This includes agents creating their own sales materials, modifying approved materials, or using outdated versions. Maintain a centralized, version-controlled library of all approved materials and restrict agent access to only current versions.
6. Complaint Tracking System
CMS requires that you have a formal process for receiving, documenting, investigating, and resolving complaints from Medicare beneficiaries. This includes both complaints received directly and those forwarded from carriers or CMS itself.
What Your Complaint Tracking System Needs
Intake Process
A documented, consistent method for receiving complaints via phone, email, mail, or carrier forwarding. Every complaint must be logged.
Investigation Workflow
A defined process for investigating each complaint, including reviewing call recordings, agent notes, and enrollment documentation.
Resolution Documentation
Written records of how each complaint was resolved, what corrective actions were taken, and communication sent to the complainant.
Trend Analysis
Regular review of complaint patterns to identify systemic issues—repeated complaints about the same agent or topic signal a training gap.
7. Enrollment Verification Procedures
CMS wants to see that you verify every enrollment is legitimate, voluntary, and based on accurate information. This protects beneficiaries from being enrolled in plans they didn't choose or don't understand.
Verification Best Practices
Implement a post-enrollment verification call or quality check for a sample of enrollments (many agencies check 100% during AEP). Verify the beneficiary understands their plan choice, confirmed their personal information, and was not pressured. Document the verification and flag any enrollments that raise concerns.
8. Plan Benefit Accuracy
Agents must present plan benefits accurately during sales calls. Misstating premiums, copays, drug coverage, provider networks, or other benefit details is a serious compliance violation that can result in enrollment reversals and CMS sanctions.
Do This
- Use carrier-provided plan comparison tools during calls
- Update plan data immediately when carriers issue changes
- Train agents to say "let me verify that" rather than guess
- Record plan benefit discussions for verification
Avoid This
- Agents quoting benefits from memory
- Using outdated plan summaries or marketing materials
- Making guarantees about coverage or costs
- Comparing plans without using approved comparison tools
9. Agent Licensing Verification
Every agent selling Medicare products must hold a valid, active insurance license in the state where the beneficiary resides. CMS auditors will check that your agency verifies licensing before agents begin selling and monitors license status on an ongoing basis.
Licensing Verification Process
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1Pre-Hire Verification: Verify license status in all relevant states before allowing any agent to sell
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2Ongoing Monitoring: Set up renewal alerts and regularly check NIPR or state databases for status changes
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3System Controls: Configure your dialer to restrict agents from calling states where they are not licensed
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4Documentation: Keep copies of all licenses, appointment confirmations, and E&O insurance certificates on file
10. Corrective Action Plans (CAPs)
When compliance issues are identified—whether through internal monitoring, agent coaching, or external complaints—you must document the corrective action taken. CMS wants to see that you don't just identify problems but actively fix them and prevent recurrence.
Elements of an Effective Corrective Action Plan
- Issue Description: Clear documentation of what went wrong and when it was identified
- Root Cause Analysis: Why did the issue occur? Training gap? Process failure? System limitation?
- Corrective Steps: Specific actions taken to address the immediate issue (agent retraining, enrollment reversal, etc.)
- Preventive Measures: Systemic changes to prevent recurrence (updated scripts, new QA checks, system restrictions)
- Follow-Up Timeline: Dates for re-evaluation to confirm the corrective actions are working
Bringing It All Together
These 10 items aren't independent checkboxes—they form an interconnected compliance ecosystem. Your call recordings support your compliance monitoring. Your training records justify your agents' ability to present plan benefits accurately. Your complaint tracking feeds into your corrective action plans. For comprehensive guidance on building this ecosystem, explore our full Medicare compliance guide.
The Technology Advantage
The right call center platform handles many of these requirements automatically—mandatory call recording, compliance script embedding, agent licensing controls, and built-in QA tools. Manual processes break down at scale. Technology-enforced compliance works every time, for every agent, on every call.
Key Takeaways
- Call recordings and SOA documentation are the foundation—without these, you fail an audit immediately
- Active compliance monitoring with documented QA processes shows CMS you take oversight seriously
- Agent training and licensing must be verified before selling begins—not documented retroactively
- Marketing materials, complaint tracking, and enrollment verification require formal, documented processes
- Corrective action plans demonstrate that you identify, fix, and prevent compliance issues proactively
CMS audits don't have to be stressful. When you have these 10 items systematically documented and consistently maintained, an audit becomes a straightforward process of producing evidence you already have. Start building these systems today—don't wait for the audit notice to arrive.
Build Audit-Ready Compliance Into Your Call Center
AgentTech Dialer includes mandatory call recording, compliance monitoring, and built-in QA tools designed for Medicare compliance.
Try AgentTech Dialer NowReferences & Authoritative Sources
The information on this page is supported by the following official and authoritative sources.
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Medicare.gov - Official U.S. Government Site Medicare.gov