Medicare Compliance Center | Pandora Insurance
Pandora Insurance · Compliance Center

Medicare Marketing & CMS Compliance

How we follow the Centers for Medicare & Medicaid Services (CMS) rules that protect Medicare beneficiaries — and where to find the official regulations, updated for the 2026 plan year and the CY 2027 Final Rule.

Last reviewed: July 2026  |  Reflects the CMS CY 2027 Final Rule (published April 2026)

Required Third-Party Marketing Organization (TPMO) Disclaimer

“We do not offer every plan available in your area. Currently we represent [X] organizations which offer [Y] products in your area. Please contact Medicare.gov, 1‑800‑MEDICARE, or your local State Health Insurance Assistance Program (SHIP) to get information on all of your options.”

Per 42 CFR §422.2267(e)(41) and §423.2267(e)(41). Replace [X] and [Y] with your actual carrier and product counts, reviewed annually before AEP.

The Rules We Follow

Key CMS marketing and communications requirements for agents and third-party marketing organizations. Each rule links to the official federal source.

In Effect

TPMO Disclaimer on All Marketing

The standard TPMO disclaimer appears on our website, emails, printed materials, and TV/print ads, and is read on sales calls. 42 CFR Part 422, Subpart V →

In Effect

Sales Call Recording & Retention

All marketing and sales calls with beneficiaries are recorded. Under the CY 2027 Final Rule, retention is reduced from 10 years to 6 years (audio required for the first 3). CMS Managed Care Marketing →

In Effect

Scope of Appointment (SOA)

A documented Scope of Appointment is collected before every personal marketing appointment, limiting discussion to the products you agree to in advance.

In Effect

Permission to Contact & Consent to Share Data

We contact beneficiaries only with valid Permission to Contact, and personal data is shared with another TPMO only with your express consent, in line with CMS and TCPA requirements.

In Effect

Material Review & HPMS Submission

Marketing materials that reference plan benefits, premiums, or cost-sharing are submitted for review through carriers via the CMS Health Plan Management System (HPMS) before use.

Oct 1, 2026

48-Hour SOA Waiting Period Removed

The CY 2027 Final Rule eliminates the 48-hour wait between collecting an SOA and holding a personal marketing appointment — beneficiaries who are ready can meet right away.

Oct 1, 2026

Flexible Disclaimer Timing on Calls

The TPMO disclaimer may be delivered at any point before plan benefits are discussed, replacing the strict 60-second call requirement.

Oct 1, 2026

Educational & Marketing Events May Run Back-to-Back

The mandatory 12-hour gap between educational and marketing events at the same venue is removed, provided attendees are clearly notified and may opt out.

Carrier Compliance Standards

Beyond CMS, every carrier we represent maintains its own compliance program. Our agents complete annual AHIP certification plus each carrier's product training before selling.

Annual Certification

Every licensed agent completes AHIP Medicare training and carrier-specific certifications each year before the Annual Enrollment Period.

AHIP Medicare Training →

Carrier Marketing Review

Any material naming a specific carrier, plan, benefit, or premium is submitted to that carrier for approval before use, per their marketing guidelines.

Secret Shopper & Oversight Programs

Our carriers monitor sales activity through call reviews, secret shopping, and complaint tracking. We report and address any compliance findings promptly.

Report a Concern

If you believe a marketing communication from us was misleading, contact us directly — or file a complaint with Medicare at 1-800-MEDICARE.

Report to Medicare →
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