Does a 2026 SOA Cover a 2027 Plan Discussion?

Not if the original SOA was to discuss 2026 plans. CMS says SOAs are valid for 12 months, but only for the agreed scope. Any discussion outside that scope requires a new SOA, and CMS specifically says that includes the same product for a different year. So an SOA to discuss contract year 2026 plans does not automatically cover contract year 2027 plans.

This is one of those questions agents ask because it sounds like it should have an easy yes-or-no answer.

You got the SOA. It is still less than 12 months old. The client wants to talk again. So can you just use the same SOA when the conversation moves into next year’s plans?

Usually, no. And the reason is that CMS treats this as a scope question, not just a calendar question. CMS says SOAs, Business Reply Cards, and other requests for additional information stay valid for 12 months from the beneficiary’s signature date or initial request date. But CMS also says that 12-month window only covers the agreed scope of products already documented in the SOA.

The short answer

If the original SOA was to discuss contract year 2026 plans, then it does not carry you into a contract year 2027 plan discussion just because the SOA is still within 12 months. CMS says any new product discussion outside the original scope requires a new SOA, and CMS gives the exact example that if there is an SOA to discuss CY 2026 plans, a new SOA is required to discuss CY 2027 plans.

That is the real takeaway agents should remember:

A still-valid SOA is not the same thing as an open-ended SOA.

Why agents get tripped up on this

The confusion comes from the fact that two things are true at the same time.

First, CMS says an SOA can stay valid for 12 months and can be used for multiple telephonic or in-person contacts or appointments. Second, CMS says that same 12-month window does not give permission to discuss products outside the scope already agreed upon, including the same product for a different year.

So if you only remember the “12 months” part, you will miss the more important part.

The 12-month rule is about how long the documented scope can stay alive. It is not a free pass to roll a prior-year discussion into a new contract year.

The practical rule: scope matters more than the date on the form

This is the cleanest way to explain it to agents.

If by “2026 SOA” you mean an SOA signed sometime in calendar year 2026, the signature date by itself is not the whole issue. On a straightforward reading of CMS’s 12-month validity rule, an SOA signed in 2026 can still remain valid into 2027 for the same agreed scope. But if by “2026 SOA” you mean an SOA to discuss 2026 plans, CMS says that does not authorize a 2027 plan discussion.

That distinction matters.

The date on the form matters for the 12-month window.
The documented scope matters for what you can actually discuss.

Why a new contract year changes the analysis

CMS requires the SOA to identify, at minimum, the type of product(s) to be discussed and says you cannot market beyond the scope agreed upon and documented in the SOA. CMS also explains that any new discussion outside that agreed scope requires a new SOA. Then CMS goes one step further and specifically says this includes the same product for a different year.

That is why this is not just a technicality.

A conversation about 2027 plans is not treated as merely a continuation of a 2026 plan conversation. CMS is telling agents to treat the contract year change as a new SOA trigger.

What the 12-month rule does let you do

The 12-month rule still matters. It gives agents more flexibility than some people realize.

Within that 12-month period, plans and agents can contact beneficiaries regarding the agreed scope already documented in the SOA, and the signed SOA can be used for multiple telephonic or in-person contacts or appointments. CMS also reminds plans and agents that they still have to respect a beneficiary’s request not to be contacted, even if the request comes during that 12-month window.

So if the scope stays the same, one SOA can support follow-up calls, another appointment, or continued discussion inside that same lane.

What it cannot do is quietly stretch into a new lane just because the form has not expired yet.

Real-world examples

Here is the practical version agents can actually use.

Example 1: You got an SOA in spring 2026 to discuss MA-PD options for 2026. The client calls back later wanting to compare 2027 plans. That is a new SOA situation, because CMS specifically says a prior SOA for 2026 plans does not cover 2027 plans.

Example 2: You got an SOA in late 2026 specifically to discuss 2027 MA-PD options during AEP, and the follow-up call happens in early 2027. On a practical reading of CMS’s rule, the mere fact that the SOA was signed in 2026 is not the problem, because the 12-month rule runs from signature date and the relevant issue is whether the follow-up stays within the same agreed scope.

Example 3: You have a broad internal habit of checking “MA-PD” on every SOA and assuming that covers next year too. That is too loose. CMS says the same product for a different year still requires a new SOA.

What should agents do in practice?

The simplest operational rule is this:

Treat a new contract year as a new SOA trigger.

That is cleaner for the beneficiary, cleaner for the file, and much easier to defend later than trying to argue that an older SOA should carry over into a new plan year discussion. CMS’s example is already pointed in that direction, so there is not much upside in getting cute with it.

The good news is that getting a new SOA is not as painful as it used to be. In the 2027 final rule, CMS finalized removal of the 48-hour waiting period, which means the SOA still has to be agreed upon and recorded before the personal marketing appointment, but there is no longer a mandatory 48-hour delay before the discussion can happen.

So the better workflow is not to reuse last year’s SOA farther than it should go. The better workflow is to collect the fresh SOA and keep moving.

One more point agents should not miss

CMS also clarified what can count as an SOA. The Agency says Business Reply Cards, voicemails, online forms, and other requests for information can function as SOAs if they include the type of product(s) to be discussed. CMS also says it does not provide a model SOA document.

That means the practical answer is not “reuse old SOAs longer.”
It is “make it easy to get a new one when the scope changes.”

Bottom line

A 2026 SOA does not automatically cover a 2027 plan discussion.

CMS says SOAs can stay valid for 12 months, but only for the scope already documented. And CMS is unusually clear on the contract-year issue: if the SOA was to discuss CY 2026 plans, a new SOA is required to discuss CY 2027 plans, even though the product category may be the same.

So the cleanest answer for agents is this: if the year changes and the plan discussion changes with it, get the new SOA. It is simpler, it matches CMS’s example, and now that the 48-hour wait is gone, it is also easier to do in real life.

If your files contain multiple SOAs for the same client across multiple plan years, Vault makes it easier to keep the old scope, the new scope, and the follow-up records organized in one place.

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.