A client gave me her neighbor's number and said she needs Medicare. Can I call her, or does she have to contact me first?
You cannot call the neighbor based on that referral — cold calls based on referrals are prohibited even though your client gave you her number.
What the rule says
“MA organizations may not do any of the following if unsolicited:”
“Use telephone solicitation (that is, cold calling), robocalls, text messages, or voicemail messages, including, but not limited to, the following:”
“Calls based on referrals.”
However, if the neighbor herself contacts you or otherwise consents to be contacted, that changes the analysis:
“Calls are not considered unsolicited if the beneficiary provides consent or initiates contact with the plan.”
So the neighbor needs to initiate contact with you (or the plan) or otherwise give her own consent to be contacted before you can call her — your client passing along the number is not enough.
Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.
This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.