Can I take an enrollment over the phone if I was the one who called the client?
Generally no. If you initiated the call, the applicant did not call in, so the phone enrollment standards for calls without an existing business relationship generally require the request to come from an incoming call from the applicant. There's a narrower exception if you called an existing enrollee about plan business and *they* express a desire to enroll during that call.
What the rule says
This CMS guidance applies to enrollment requests received on or after January 1, 2027 (plans may apply it to AEP enrollments effective January 1, 2027).
“Generally, plans may only accept requests for enrollment:”
“Through an incoming (in-bound) telephone call to a plan representative or agent.”
“During communications initiated by the organization when, during the course of outreach to provide information about their Medicare plan offerings to individuals with whom they have an existing business relationship, the individual expresses a desire to enroll in one of the organization's plans.”
“For applicants without an existing business relationship with the organization, enrollment requests can only be accepted during an incoming call from the applicant”
The excerpt also touches on when a plan/agent may call current or former members to discuss "plan business":
“A Part D sponsor may conduct the following activities as plan business:”
“Call current enrollees, including those in non-Medicare products, to discuss Medicare products.”
Whether taking the enrollment over the phone would fit here depends on whether the client already had an existing business relationship with your organization and whether the call was to discuss "plan business" under § 422.2264(b)/§ 423.2264(b), versus a cold outbound call to a new prospect, which the excerpts do not authorize for accepting enrollment.
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.