Can You Collect an SOA at an Educational Event Again?

Yes. In the CMS 2027 final rule, CMS reversed the 2023 ban and again permits plans and agents/brokers to make available and receive Scope of Appointment forms at educational events. But the event still has to stay educational: sales and marketing activities remain prohibited at educational events, and if a marketing event follows, beneficiaries must be told the educational event is ending and given a sufficient opportunity to leave before the marketing event begins.

For agents, this is one of the most useful 2027 changes because it fixes a very real workflow problem.

A beneficiary comes to an educational event, asks good questions, and clearly wants a follow-up conversation. Under the 2023 rule, you could get contact information, but not the SOA itself. That created extra steps, extra follow-up, and extra chances for the beneficiary to disappear before the real appointment ever got scheduled. CMS changed course in the 2027 final rule, and the new marketing and communications policies apply for contract year 2027 marketing beginning October 1, 2026.

So the practical answer is now simple:

Yes, you can collect the SOA at the educational event again.
Just do not confuse that with permission to start selling at the educational event itself.

What changed

CMS’s position on this has moved around over the last few years.

In the January 2021 final rule, CMS allowed plans and agents/brokers to obtain beneficiary contact information, including SOA forms, at educational events. Then in the April 2023 final rule, CMS changed course and prohibited plans and agents/brokers from making available and receiving SOA forms at educational events, even though other contact information like Business Reply Cards could still be collected. In the 2027 final rule, CMS reversed that 2023 ban and returned to allowing SOAs at educational events.

That is why the word again matters here. This is not a brand-new concept. It is CMS rolling back a more recent restriction and going back to a more workable approach.

Why CMS changed its mind

CMS’s reasoning was practical.

CMS said the statute still prohibits sales and marketing activities at educational events, but it does not prohibit collecting an SOA there. CMS drew a line between those concepts and said collecting an SOA is not itself a sales or marketing activity. Instead, CMS described the SOA as an agreement about what type of product or products will be discussed later, in advance of a personal marketing appointment.

CMS also said allowing SOAs at educational events reduces burden on beneficiaries, plans, and agents/brokers. The agency specifically pointed to the convenience of scheduling follow-up appointments without forcing the beneficiary to reconnect later or travel back to find the plan or agent after the event ends. CMS acknowledged that it had previously worried about pressure on beneficiaries, but said those concerns were outweighed by the value of improving timely access to plan information.

So what can you do at an educational event now?

You can make SOA forms available at the event, and you can receive completed SOAs from beneficiaries at that same event. CMS finalized that change by revising the regulatory text so educational-event contact can include both Business Reply Cards and Scope of Appointment forms.

That means if someone attends your seminar and wants a follow-up conversation about MA, MA-PD, or PDP options, you do not have to wait until after the event to get the scope documented. You can handle that step right there, as long as the event itself remains educational.

And this is where the rule becomes especially useful in real life: if you need a replacement SOA because an older one covered a prior scope or even a prior contract year, an educational event is now a compliant place to collect that fresh SOA before the later discussion happens. CMS says SOAs are valid for 12 months only within the agreed scope, and a new SOA is required for discussions outside that scope, including the same product for a different year.

What you still cannot do

This is the part agents should keep straight.

CMS did not turn educational events into sales seminars. CMS repeatedly said that sales and marketing activities are still prohibited at educational events, and it also said the distinctions and beneficiary protections between educational events and marketing or sales events remain in place.

In practical terms, that means collecting the SOA does not open the door to start comparing specific plans during the educational presentation just because the person signed something. The SOA is permission for the later personal marketing appointment. It is not a loophole that changes the nature of the educational event itself. That is an inference from the way CMS separates SOA collection from the still-active ban on sales and marketing activity at the event.

Can you move from an educational event into a marketing event the same day?

Yes, and that is another reason this change matters.

CMS also removed the old 12-hour delay rule. A marketing event can now directly follow an educational event in the same location, as long as beneficiaries are told that the educational event is ending, that a marketing event will begin shortly, and they are given a sufficient opportunity to leave before the marketing event starts. CMS even gave a brief restroom or snack break as an example of a sufficient opportunity to leave.

So the modern 2027 event workflow can look much cleaner than it used to. You can hold the educational event, collect SOAs from people who want follow-up, and—if you are also running a marketing event afterward—move into that next phase the same day with the required notice and real opt-out opportunity. What you cannot do is blur the line so much that attendees are never clearly told the educational portion has ended.

What should the SOA include if you collect it at the event?

CMS said the SOA must identify, at minimum, the type of product or products to be discussed. CMS gave examples such as MA plans, MA-PD plans, and standalone PDPs. CMS also encouraged, as a best practice, including other information like the appointment date and beneficiary contact information.

That means the best event SOA is not vague. It should make it easy to tell later what the beneficiary actually agreed to discuss. If the product scope is unclear, the value of collecting the SOA at the event drops fast.

CMS also said it does not provide a model SOA document or SOA scripts. So there is flexibility in format, but not in the underlying purpose: the record still has to capture the agreed scope clearly enough to support the later appointment.

Does the follow-up appointment still need a written SOA if it is in person?

Yes.

CMS separately clarified in the 2027 rule that for an in-person personal marketing appointment, the SOA must be in writing before the appointment starts. So if you collect the SOA at an educational event and the next step is a face-to-face meeting, that written record matters.

That is another reason this rule change is useful. If the beneficiary is already there and wants to move forward, you can now gather the written SOA at the educational event instead of trying to chase it down later.

A practical event workflow that actually works

The clean version looks like this.

Run the educational event as an educational event. Keep the content broad and informational. If attendees want a follow-up conversation, make the SOA available and collect it there, with the product scope documented. If you are holding a later marketing event in the same location, clearly announce that the educational event is ending, tell attendees that the marketing event will begin shortly, and give them a real chance to leave before that next event starts. If the later conversation becomes a personal in-person marketing appointment, make sure the written SOA is already in place and stay within the agreed scope.

The biggest mistake to avoid

The mistake is thinking that because SOAs are back at educational events, the educational event itself became more sales-oriented.

It did not. CMS made a narrower change than that. The agency said SOA collection is allowed again because it is not, by itself, a sales or marketing activity. But CMS also explicitly kept the broader prohibition on sales and marketing activities at educational events and preserved the distinction between educational events and marketing events.

So the safest mental model is this:

The SOA can be collected at the event.
The selling still belongs in the right setting.

Bottom line

Yes, you can collect an SOA at a Medicare educational event again.

CMS reversed the 2023 ban in the 2027 final rule and once again allows plans and agents/brokers to make available and receive SOA forms at educational events. That makes it much easier to schedule follow-up appointments, gather replacement SOAs when the scope changes, and avoid losing beneficiaries in the handoff between education and next steps.

But the event still has to stay educational. Collecting the SOA is allowed because CMS does not treat it as sales or marketing activity. The prohibition on sales and marketing at educational events remains, and if you transition into a same-day marketing event, the beneficiary still has to be told that change is happening and given a sufficient opportunity to leave.

If you are going to collect more SOAs at seminars, community talks, and educational meetings again, the next problem is not the rule. It is organization. Vault gives you one place to keep those event-collected SOAs tied to the later appointments they were supposed to support.

This article is for educational purposes only and is not legal advice. Agents should review current CMS guidance, carrier rules, and agency policies, and consult qualified counsel or compliance professionals for specific requirements.