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Excellus Updated CMS Guidance on Call Recording & AEP Best Practices

November 3, 2022

Excellus recently received updated guidance from CMS on a few different topics that are important to review with you.  Please review and share this information with your agents/brokers and appropriate downlines.


TPMO Call Recording

CMS released an FAQ document (attached) that gives additional details on the TPMO call recording regulation for all agents/brokers (both captive & independent).  The updated guidance now specifies that ALL calls – inbound and outbound must be recorded (not just “sales” calls, ALL calls).  Additionally, Zoom calls and other calls using virtual presence technology must be recorded.


CMS also indicted they will be “secretly shopping marketing events by reviewing television, print and internet marketing and calling related phone numbers and/or requesting information via online tools” to ensure compliance to these new regulations.



Best Practices and Reminders for Medicare Advantage Organizations and Part D sponsors

CMS also released a memo outlining best practices for MAPD plans during AEP. They specifically call out the requirement for all agents to review the required “pre-enrollment checklist” with each beneficiary prior to enrollment.  All items on the checklist must be covered in full and understanding of them acknowledged by the beneficiary.  Excellus/Univera’s new 2023 Medicare Advantage Enrollment “book/kit” include pre-enrollment checklists for both the HMO & PPO plans.  This is typically standard procedure when meeting with beneficiaries, but Excellus would like to call this out as a reminder since CMS issued this memo so they are highlighting the importance.

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