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Molina Phone Recording Reminder

October 26, 2022
Molina Healthcare

Who has to record Medicare Advantage enrollment calls? 

CMS issued its 2023 Final Rule in May, which includes the new call recording requirements for Medicare Advantage enrollments. CMS subsequently posted FAQs to the Managed Care Marketing site on 10/19/2022.

The marketing requirements:

  • Apply to all health care agents who enroll new and existing Medicare beneficiaries in MA plans
  • Mandate storage of telephonic sales and enrollment recordings in a HIPAA-compliant manner for at least 10 years

Compliance with CMS regulations is mandatory. For more information, read the highlights below, and see the FAQ document posted on the CMS website.


All organizations and agents are required to make the following disclaimer within the first minute of every inbound and outbound sales phone call: (if applicable) - “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 your options.”

All organizations and agents are also required to make this disclaimer: "This call is recorded for quality assurance purposes. You are not required to provide any health-related information unless it will be used to determine eligibility for enrollment into a health plan. I’m going to continue now if that’s all right. May I continue?"

If a beneficiary refuses to agree to being recorded, the agent cannot complete the enrollment. There are no exceptions to this CMS requirement.


Phone: The rules apply to any marketing call starting when a beneficiary is made aware of a plan to the end of the enrollment process.

Virtual Forums: Zoom calls and other calls using virtual technology between a Medicare beneficiary and an organization or individual must be recorded.

In-person: CMS does not require recording of in-person communications.


Molina Medicare can help you by providing tools compliant with these new regulations.

Electronic: We recommend electronic submissions every time possible, and we offer DRX/Connecture software for brokers to use for online enrollments. It provides free call recording, retention, eligibility confirmation for Medicare, and the fastest enrollment processing possible. Please use your standard log-in and password for DRX/Connecture and follow the prompts

Telephonic: For telephonic submissions, please see our job aid, The Telephonic Enrollment Process, posted on the Molina Agent Center. You will complete and upload a Telephonic Enrollment Form and then engage in a 3-way call with Molina and the beneficiary. The telephonic team records and stores the sales call for you.

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Questions? Call us at 855-888-8326.

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