Year-End Compliance Review: Closing the Books on Call Center Compliance
The end of the year is more than a calendar milestone—it is your organization's last chance to identify compliance gaps, close out corrective actions, and set the foundation for a clean start in the new plan year. This comprehensive review checklist covers every area a Medicare call center must audit before closing the books on the current year.
The 7-Point Year-End Compliance Checklist
1. Recording Audits
Your call recordings are the single most important piece of compliance evidence your organization holds. A year-end recording audit verifies that your recording infrastructure has been functioning correctly, that all mandated calls were captured, and that recorded calls meet CMS quality and content standards. As detailed in our CMS audit readiness checklist, recordings are typically the first item auditors request.
Recording Audit Checklist
2. Consent Verification
Recording consent and permission-to-contact documentation must be verifiable for every call made during the year. Year-end is the time to audit your consent capture process and identify any systematic gaps that could expose your organization to TCPA liability or CMS penalties.
Two-Party Consent State Audit
For calls involving beneficiaries in two-party consent states (California, Florida, Illinois, Maryland, etc.), verify that explicit verbal consent was obtained and captured on the recording. A missing consent statement on even one call to a two-party state creates litigation exposure. Review our Medicare compliance guide for state-specific requirements.
Consent Best Practices
- Automated consent prompts at call start
- Timestamp logging of consent capture
- Separate consent storage linked to recording
- Quarterly consent audit during the year
Consent Red Flags
- Recordings that start mid-conversation
- No verbal consent captured on recording
- Agent skipping consent for "returning callers"
- Passive consent assumptions in two-party states
3. DNC List Updates and Compliance
Do Not Call list compliance is a year-round obligation, but year-end is the critical checkpoint to ensure your systems are current and your processes are airtight. TCPA penalties for DNC violations can reach $46,517 per call as of 2026, making this one of the highest-risk compliance areas for any call center.
DNC Year-End Audit Items
- National DNC registry sync — Verify your system has pulled the latest national DNC list within the past 31 days and is configured for automatic monthly updates
- Internal DNC list review — Audit your internal suppression list for completeness. Ensure every beneficiary who requested no further contact has been properly added
- State DNC registries — Confirm compliance with state-level DNC registries for every state where you operate or make calls
- DNC complaint log review — Review all DNC-related complaints received during the year. Identify root causes and verify corrective actions were implemented
- Scrubbing process verification — Test your DNC scrubbing process by running a known DNC number through the system to confirm it is properly blocked
4. Agent License Renewals
Every agent who handled Medicare calls during the year must have maintained valid state insurance licenses for every state where they sold. Year-end is the time to verify current license status, identify upcoming expirations, and create a renewal calendar for the coming year. An unlicensed agent making a single Medicare sales call creates immediate regulatory exposure for your entire organization.
License Management Year-End Tasks
License Verification
Verify current license status for every active agent across all states where they sold during the year. Document any gaps.
Renewal Calendar
Build a 12-month renewal calendar for the coming year with 60-day advance alerts for every upcoming license expiration.
CE Credit Tracking
Confirm all agents have completed required continuing education credits. Many states require CE completion before renewal.
Appointment Verification
Verify carrier appointments are active for every agent-carrier-state combination where sales occurred during the year.
5. CMS Documentation Review
CMS requires extensive documentation that goes beyond call recordings. Year-end is the time to verify that every required document is complete, properly filed, and accessible. If a CMS audit arrives in the new year, you need to be able to produce documentation for the entire previous year within a reasonable timeframe. For the complete framework, refer to our CMS penalties guide to understand what is at stake.
CMS Documentation Inventory
6. Corrective Actions Review
Every compliance issue identified during the year should have generated a corrective action. Year-end is when you verify that every corrective action was completed, effective, and documented. Open corrective actions heading into a new year signal to auditors that your compliance program lacks follow-through.
Critical: Close All Open Items
CMS views open corrective actions as evidence of ongoing compliance failures. Every corrective action from the current year must be either completed and documented, or escalated with a documented timeline for resolution. There should be zero unaddressed compliance findings heading into the new year.
Corrective Action Review Process
| Step | Action | Documentation Required |
|---|---|---|
| 1 | Inventory all corrective actions opened during the year | Master corrective action log |
| 2 | Verify completion status of each item | Completion evidence and sign-off |
| 3 | Assess effectiveness of completed actions | Before/after metrics comparison |
| 4 | Escalate any open items with resolution timelines | Escalation memo with target dates |
| 5 | Identify systemic patterns across corrective actions | Trend analysis report |
7. Training Records
CMS expects that every agent who handled Medicare calls was properly trained before making their first call and received ongoing training throughout the year. Year-end is when you verify that training documentation is complete, current, and defensible in an audit. Training records that cannot be produced are treated the same as training that did not happen.
Training Record Requirements
- Initial compliance training — Documentation proving each agent completed compliance training before handling Medicare calls, including date, content covered, and assessment scores
- Annual carrier certifications — Proof of completion for every carrier-required annual certification, filed by agent and carrier
- Ongoing compliance refreshers — Records of quarterly or monthly compliance training sessions, attendee lists, and topics covered
- Remedial training records — Documentation of additional training provided to agents who failed QA reviews or were involved in compliance incidents
- Product and plan training — Evidence that agents were trained on specific plan benefits, limitations, and changes for each plan year they sold
Building Your Year-End Compliance Report
Once each audit area is complete, compile findings into a formal year-end compliance report. This document serves as both an internal accountability tool and evidence of your compliance program's maturity. Share it with executive leadership, compliance committee members, and retain it for potential CMS audit requests.
Year-End Compliance Report Structure
Executive Summary
High-level compliance status, key metrics, and areas requiring attention heading into the new year.
Audit Findings by Area
Detailed findings for each of the 7 compliance areas, including pass/fail metrics and supporting evidence.
Corrective Action Summary
Status of all corrective actions, effectiveness assessments, and any items carrying over into the new year.
Next Year Action Plan
Recommendations for compliance program improvements, budget requests, and technology needs for the coming year.
Key Takeaways
- Recording audits verify completeness, quality, and compliance content across the year's entire call library
- Consent and DNC compliance must be verified systematically—a single gap can result in five-figure per-call penalties
- License and certification records must confirm every agent was properly authorized for every call they handled
- All corrective actions from the year must be closed or escalated with documented resolution timelines
- A formal year-end compliance report demonstrates program maturity and prepares your organization for any CMS audit in the coming year
Year-end compliance review is not a one-day exercise—it is a structured process that should begin at least four to six weeks before year-end to allow adequate time for thorough auditing, gap remediation, and documentation. The call centers that treat this review as a serious operational event—rather than a checkbox—are the ones that enter each new year with confidence and audit readiness.
Start the New Year Audit-Ready
AgentTech Dialer provides built-in compliance monitoring, automated recording audits, and complete audit trail documentation—making your year-end compliance review faster and more thorough.
Try AgentTech Dialer NowReferences & Authoritative Sources
The information on this page is supported by the following official and authoritative sources.
- 1
-
2
TCPA - 47 U.S. Code § 227 U.S. Code
-
3
Medicare.gov - Official U.S. Government Site Medicare.gov