Telephonic Scope of Appointment (T-SOA): How to Stay Compliant on Every Call
For Medicare call centers, the Telephonic Scope of Appointment (T-SOA) is often the most practical way to obtain beneficiary consent before a sales conversation. But unlike paper or electronic SOAs, the T-SOA relies entirely on a recorded verbal exchange—and CMS holds call centers to exacting standards on how that exchange is conducted, recorded, and retained. One missed scripting element, a dropped recording, or a blurred line between the T-SOA call and the sales call can result in compliance violations that threaten your entire Medicare operation. This guide walks through the complete T-SOA process step by step, covering scripting requirements, recording rules, inbound vs. outbound differences, and how technology can automate compliance from start to finish.
What Is a Telephonic Scope of Appointment (T-SOA)?
A Telephonic Scope of Appointment is a verbal version of the standard CMS Scope of Appointment form, completed over the phone and captured on a recorded call. Instead of the beneficiary signing a physical or electronic document, they verbally confirm which Medicare product categories they agree to discuss, and the recorded call serves as the official compliance documentation.
CMS explicitly allows the T-SOA as a valid method for obtaining beneficiary consent, recognizing that many Medicare sales interactions begin with a phone call rather than an in-person visit. However, the telephonic format introduces unique compliance requirements that don't apply to paper or electronic SOAs—most notably, the obligation to record the entire T-SOA conversation and retain that recording for 10 years.
T-SOA vs. Other SOA Methods
- Paper SOA: Signed physically—impractical for phone-based sales operations
- Electronic SOA (E-SOA): Signed digitally via email or web portal—good for tech-savvy beneficiaries
- Telephonic SOA (T-SOA): Verbal confirmation on a recorded call—ideal for call centers handling high volume
For a broader overview of all SOA methods and the underlying CMS rules, see our complete Scope of Appointment rules guide.
The Step-by-Step T-SOA Capture Process
A compliant T-SOA call follows a precise sequence. Every step must be completed, captured on the recording, and verified before the call ends. Skipping any element—or performing them out of order—can invalidate the entire SOA and expose your agency to CMS enforcement actions.
T-SOA Call Sequence
Inform the beneficiary that the call is being recorded. This must happen at the very start of the call, before any SOA language is read. The recording disclosure satisfies both CMS requirements and state wiretapping laws.
The agent identifies themselves by name, states the name of the agency or plan sponsor they represent, and explains that the purpose of the call is to obtain a Scope of Appointment for a future Medicare discussion.
The agent reads the required CMS language explaining that the beneficiary is under no obligation to enroll, that the discussion will be limited to the products they select, and that they may end the appointment at any time.
The agent lists each available product category one at a time—Medicare Advantage, Medicare Supplement, Part D, dental/vision/hearing, etc.—and asks the beneficiary to confirm or decline each one.
After all product categories have been presented, the agent reads back the selected products and asks the beneficiary for a final "yes" confirming the overall Scope of Appointment.
The agent confirms the date and time of the scheduled sales appointment and verifies it is at least 48 hours after the current T-SOA call (unless the beneficiary-initiated exception applies).
The call ends and the recording is automatically tagged as a T-SOA call, linked to the beneficiary's record, and queued for 10-year retention.
T-SOA Scripting Requirements
Unlike a casual phone conversation, the T-SOA call must follow a structured script that includes specific language mandated by CMS. Agents should read the script verbatim—paraphrasing or summarizing CMS-required language is not acceptable and can invalidate the SOA during an audit review.
Required Script Elements
- Recording disclosure: "This call is being recorded for quality assurance and compliance purposes."
- Agent identification: Full name, agency name, and the plan sponsor(s) represented
- Purpose statement: "The purpose of this call is to obtain your Scope of Appointment, which documents the types of Medicare products you would like to discuss at a future appointment."
- No obligation statement: "You are under no obligation to enroll in any plan as a result of this appointment."
- Product category listing: Each product type read individually with a pause for beneficiary confirmation
- Summary and final confirmation: "To confirm, you have agreed to discuss [products]. Is that correct?"
- Appointment scheduling: Date, time, and confirmation of the 48-hour window
Script Deviation Warning
Agents who paraphrase, skip, or rush through CMS-required language create audit risk even when the beneficiary clearly consented. CMS auditors compare recorded T-SOA calls against the required elements checklist. If the recording shows the agent summarized the no-obligation statement rather than reading it verbatim, the SOA may be deemed non-compliant—regardless of the beneficiary's intent.
Recording Requirements for T-SOA Calls
The T-SOA recording is the compliance documentation. Unlike paper or electronic SOAs where the signed document serves as proof, the T-SOA relies entirely on the audio recording to demonstrate that the beneficiary gave informed, voluntary consent. This makes recording quality and retention absolutely critical.
Full Call Capture
The recording must capture the complete T-SOA conversation from start to finish—no partial recordings, no gaps, no edits. Both sides of the conversation must be clearly audible.
Audio Clarity
The recording must be clear enough that an auditor can understand every word spoken by both the agent and the beneficiary. Background noise, poor connections, or low volume can render a T-SOA invalid.
10-Year Retention
T-SOA recordings must be retained for a minimum of 10 years from the date of the call. Your storage infrastructure must guarantee file integrity and accessibility across this entire period.
Record Linking
Each T-SOA recording must be linked to the beneficiary's contact record and the corresponding sales call recording, enabling instant retrieval during CMS audits.
For a comprehensive look at CMS call recording obligations beyond T-SOA, see our dedicated CMS call recording requirements guide.
Inbound vs. Outbound T-SOA: Key Differences
The T-SOA process differs depending on whether the beneficiary called you (inbound) or you called the beneficiary (outbound). The most significant difference involves the 48-hour waiting period—and getting this wrong is one of the most common compliance mistakes call centers make.
Inbound (Beneficiary-Initiated)
- Beneficiary contacts your center first
- 48-hour rule may be waived if they request immediate discussion
- T-SOA and sales call can occur on the same call
- Must document that contact was beneficiary-initiated
- Still must complete all T-SOA script elements
Outbound (Agent-Initiated)
- Your center contacts the beneficiary
- 48-hour rule strictly applies—no exceptions
- T-SOA and sales call must be separate calls
- Must schedule future appointment after SOA
- Dialer must enforce 48-hour block automatically
Inbound Exception Best Practice
Even when the beneficiary-initiated exception applies, best practice is to clearly state on the recording: "I want to confirm that you called us today and are requesting to discuss Medicare products at this time." This creates an unambiguous audit trail documenting that the 48-hour waiver is legitimate. Without this explicit statement, a CMS auditor reviewing the recording may not be able to distinguish an inbound call from an outbound one.
Common T-SOA Mistakes That Trigger Violations
Even experienced call centers make T-SOA errors. These are the mistakes that most frequently appear in CMS audit findings and CTM complaint investigations:
The agent captures the T-SOA and immediately transitions to a sales pitch on the same outbound call, violating the 48-hour separation requirement.
The agent forgets or abbreviates the CMS-required statement that the beneficiary is under no obligation to enroll, rendering the T-SOA non-compliant.
The agent suggests which products the beneficiary should select—"You'll want to hear about Medicare Advantage"—instead of letting the beneficiary choose freely.
The recording starts late (missing the opening disclosure), has audio gaps, or was never saved due to a system failure. Without a complete recording, there is no valid T-SOA.
The agent reads through the product categories but never obtains a clear "yes" from the beneficiary as a final confirmation of the overall Scope of Appointment.
An inbound call bypasses the 48-hour wait, but the recording doesn't contain a clear statement confirming the call was beneficiary-initiated, making the exception unverifiable.
Technology Solutions for T-SOA Compliance
Manual T-SOA management—relying on agents to follow scripts perfectly, supervisors to spot-check recordings, and spreadsheets to track 48-hour windows—breaks down as your call center scales. Technology automates the most error-prone parts of the process, turning compliance from an ongoing struggle into a system-enforced guarantee.
On-Screen Script Prompting
Display the T-SOA script on the agent's screen with step-by-step prompts. The agent clicks through each section, ensuring no required element is skipped.
Automated 48-Hour Enforcement
The dialer automatically prevents sales calls to beneficiaries until the 48-hour window has elapsed, eliminating human error in timing compliance.
AI Script Verification
AI analyzes every T-SOA recording to verify that all required script elements were delivered. Non-compliant calls are flagged for supervisor review automatically.
Auto-Tagging and Linking
T-SOA recordings are automatically tagged, linked to the beneficiary's compliance file, and stored in a 10-year retention archive—no manual filing required.
Building a Bulletproof T-SOA Workflow
A compliant T-SOA workflow isn't just about individual call quality—it's about building operational systems that make compliance automatic. Here's how leading Medicare call centers structure their T-SOA operations:
Operational Workflow Best Practices
-
Separate T-SOA queue from sales queue
Create a dedicated call queue or disposition type for T-SOA calls. This provides clear separation between SOA and sales activities in your reporting and makes it easy to pull T-SOA calls for audit review. -
Lock the script in your dialer
Use guided scripting that requires agents to click through each T-SOA element. The agent cannot proceed to the next step until they've completed the current one, ensuring 100% script adherence. -
Automate callback scheduling
After a T-SOA call, the system automatically schedules the sales callback 48+ hours later. The lead is locked from the agent's call list until the window opens. -
QA every T-SOA call for the first 30 days
New agents should have 100% of their T-SOA calls reviewed by a compliance supervisor during their first month. After that, move to random sampling—but never less than 10% of all T-SOA calls. -
Run weekly compliance reports
Generate reports showing T-SOA completion rates, script adherence scores, 48-hour compliance rates, and recording quality metrics. Address any patterns before they become systemic issues.
For a broader view of Medicare compliance beyond T-SOA, including marketing rules and enrollment guidelines, see our comprehensive Medicare compliance guide.
Conclusion: Make T-SOA Compliance Automatic
The Telephonic Scope of Appointment is the compliance foundation for every Medicare sales call your center makes. When done right, it protects beneficiaries, protects your agency, and creates an audit trail that withstands CMS scrutiny. When done wrong—or inconsistently—it becomes the single point of failure that can unravel your entire Medicare operation.
The agencies that achieve perfect T-SOA compliance aren't the ones with the most disciplined agents—they're the ones with systems that make non-compliance impossible. Guided scripts, automated 48-hour enforcement, AI-powered recording verification, and auto-tagging create a workflow where agents physically cannot skip steps, and every call is automatically archived and linked for instant retrieval.
Don't leave T-SOA compliance to manual processes. Automate it, monitor it, and make it the strongest link in your compliance chain rather than the weakest.
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AgentTech Dialer provides guided T-SOA scripting, automatic 48-hour enforcement, AI-powered recording verification, and 10-year compliant archiving—everything your call center needs to stay CMS-compliant on every single call.
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