< Agent Blog
Sep
23
,
2022

Highmark Third Party Marketing Organization Call Recording Requirements - UPDATED

September 23, 2022

Third Party Marketing Organization Call Recording Requirements Relevant to Individual Agents

On May 9, 2022 CMS published a final ruling announcing policy and regulatory revisions for Contract Year 2023. Among the changes are requirements for disclaimers and call recording. Required implementation of these measures begins October 1, 2022.

The Standard Disclaimer


When speaking with a prospective enrollee, third-party marketing organizations (TPMOs) MUST USE the following standardized disclaimer: “We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options.”

  • This disclaimer must be provided verbally, electronically, or in writing. When communicating via phone this must be disclosed within the first minute of the call.
  • This disclaimer must also be disclosed in face to face meetings.

Call Recording Requirements

TPMOs must record all sales calls in their entirety. Sales calls may include, but are not limited to, appointment setting, preliminary plan reviews, and enrollments.

  • In Pennsylvania and Delaware, all involved parties must consent to call recording to continue the call.
  • ̶ ̶I̶n̶ ̶W̶e̶s̶t̶ ̶V̶i̶r̶g̶i̶n̶i̶a̶ ̶a̶n̶d̶ ̶N̶e̶w̶ ̶Y̶o̶r̶k̶,̶ ̶o̶n̶l̶y̶ ̶o̶n̶e̶ ̶p̶a̶r̶t̶y̶ ̶m̶u̶s̶t̶ ̶c̶o̶n̶s̶e̶n̶t̶ ̶t̶o̶ ̶c̶a̶l̶l̶ ̶r̶e̶c̶o̶r̶d̶i̶n̶g̶ ̶t̶o̶ ̶c̶o̶n̶t̶i̶n̶u̶e̶ ̶t̶h̶e̶ ̶c̶a̶l̶l̶. (See further update below)
  • Call recordings must be retained in a HIPAA compliant manner for 10 years.

For a more detailed overview of these requirements, click here.

Update - October 24, 2022

Highmark would like to share some additional guidance that has recently come to their attention, regarding face to face virtual interactions and what to do if a prospect or member does not want to be recorded. Please be aware:

  • Face to face virtual interactions on platforms like Zoom MUST be recorded.
  • If the prospect or member does not want to be recorded, you should stop the recording and you MUST END the call
View Details >View Details >

Questions? Call us at 855-888-8326.

Don't have a MedCareValue page yet?

Get Your FREE Site >

Posts you may be interested in...

Read More

Attention: Molina 2025 & 2026 Agent Onboarding

July 7, 2025
Agent Blog Icon - Indicates this is a blog article.

If an agent does not complete a 2025 onboarding invite by July 7, the onboarding invitation will be canceled

Read More

New Wellabe incentives start this month

July 7, 2025
Agent Blog Icon - Indicates this is a blog article.

New sales incentives kicked off on July 1, and you have even more opportunities to bring home extra cash.

Read More

New UPMC CRM is launching soon!

July 7, 2025
Agent Blog Icon - Indicates this is a blog article.

Evolve will allow users to seamlessly transition their current business

Read More

Gerber Life Email Address Deactivation Notice

July 7, 2025
Agent Blog Icon - Indicates this is a blog article.

Email address will be deactivated as of August 31, 2025 and will no longer be monitored after that date.

Read More

Excellus BCBS Medicare Broker News Vol. 7 No. 7

July 2, 2025
Agent Blog Icon - Indicates this is a blog article.

Important D-SNP Plans Information | Preparing For AEP - Core And Retail Trainings

Read More

Excellus BCBS Broker News Vol. 20 No. 7 Special Issue

July 1, 2025
Agent Blog Icon - Indicates this is a blog article.

2026 Large Group Product Updates And Reminders

Who we are & what we do.

Choosing an FMO to work with is not just about having access to top insurance products and commissions, it’s about finding a one-on-one agent service that is prepared to meet your needs.  

Get to know us, and see how we can help you take your business to the next level.

Learn More

Helpful Links

New Here?

We love meeting new people! Fill out the form below, and one of our sales directors will get in touch with you shortly.

Thank you! Your form has been received!
Oops! Something went wrong while submitting the form