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My client wants to discuss a product that wasn’t listed on the SOA. Do I need a new one before we continue?

Yes. If the beneficiary wants to discuss a plan type not listed on the original Scope of Appointment (SOA), you need a new SOA covering that product type before continuing.

What the rule says

“Secure and document a Scope of Appointment prior to a personal marketing appointment.”
42 CFR § 422.2274(b)(3) / § 423.2274(b)(3)

CMS guidance explains this more directly for the situation you're describing:

“A new SOA is required if the beneficiary requests information regarding a different plan type than previously agreed upon.”
MCMG § 422.2267(e) / 423.2267(e)

The guidance also confirms that "product types to be discussed" is one of the required elements on the SOA form itself:

“The following requirements must be on the scope of appointment form or on the recorded call: • Product types to be discussed.”
MCMG § 422.2267(e) / 423.2267(e)

So the regulation sets the baseline requirement (an SOA before a personal marketing appointment), and the MCMG clarifies that a change in requested product type triggers the need for a new one.

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 24, 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.

Sources cited

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