Do Medicare Agents Still Need to Keep Call Recordings for 10 Years?

For CY2027, CMS finalized a more specific retention framework for Medicare Advantage and Part D marketing and sales call recordings. Those calls must be retained for a minimum of six years. For the first three years, the record must remain in audio format. For years four, five, and six, the record may be kept as either audio or a complete and accurate transcript. CMS also made clear that this change does not eliminate the separate 10-year retention track for enrollment records. You can review the rule in the Federal Register.

So the practical answer is this: Medicare agents generally should not treat every call recording as a flat 10-year audio-retention obligation anymore. But they also should not assume the 10-year requirement disappeared.

The real question is: what kind of record is it?

The short answer

For CY2027, Medicare call recording retention breaks down like this:

That means the old “10 years for every Medicare call recording” shortcut should be replaced with a more careful workflow: six-year retention for marketing and sales recordings, 10-year retention for enrollment records, and organized storage for everything connected to the file.

What changed under the CY2027 rule?

CMS stated that MA organizations and Part D sponsors had previously been expected to retain sales and marketing call recordings for 10 years, consistent with broader record-retention and access-to-records requirements. For CY2027, CMS revised the marketing and sales call recording retention period from 10 years to six years while maintaining the separate 10-year requirement for enrollment records.

CMS explained the reason for the change in practical terms: audio files are large, long-term storage is expensive, and CMS said it is highly unlikely to review marketing and sales calls past the six-year mark. CMS also said marketing complaint reviews are most useful when they occur closer to the time of the beneficiary complaint.

The final rule did not remove call recording. CMS finalized the six-year retention policy and allowed complete and accurate transcripts during the last three years of the six-year period. The final rule summary states that all marketing and sales calls, including the audio portion of calls conducted through web-based technology, must be recorded and retained in their entirety for at least six years.

Years 1-3: keep the audio

The most important operational point is that agents should not replace audio with transcripts too early. For the first three years of the marketing and sales call retention period, CMS requires the records to be maintained in audio format.

That means a CRM note, AI summary, call recap, or short transcript is not enough for years one through three. Those tools can help you manage the file, but they do not replace the required audio during the first three years.

For agents, the practical workflow is simple:

• Record the applicable marketing or sales call.
• Store the audio in a system built for long-term retrieval.
• Keep the recording connected to the beneficiary, SOA, plan discussion, and related sales file.
• Do not rely only on notes or summaries during the first three years.

This is where a generic phone recorder often falls short. Recording the call is only step one. The harder part is keeping the recording findable and connected to the rest of the compliance file.

Years 4-6: audio or complete and accurate transcript

For years four, five, and six, CMS allows the marketing and sales call record to be maintained either as audio or as a complete and accurate transcript. CMS describes a complete and accurate transcript as one that documents the full recording and reflects all statements made by the participants as they originally occurred.

That language matters. A summary is not the same thing as a complete transcript. A sales note is not the same thing as a complete transcript. A short AI recap is not the same thing as a complete transcript.

A transcript used for retention should be treated as a compliance record, not just a convenience feature. It should be complete, accurate, tied to the original call, stored with the related file, and retrievable if a carrier, agency, plan, compliance team, CMS reviewer, or beneficiary complaint process requires it.

Does the 10-year rule still apply to anything?

Yes. This is the part agents need to be careful about. CMS specifically stated that the CY2027 proposal modified the retention requirements for the marketing and sales portions of calls, while maintaining the requirement that enrollment records be retained for 10 years. CMS also stated that it did not remove applicable enrollment documentation and retention requirements in other regulations.

For phone enrollments, CMS explained that the enrollment portion of the call serves as the enrollment form and provides proof that the beneficiary attested to the intent to enroll. CMS also described the enrollment portion as beginning when the beneficiary is advised that they are completing an enrollment request, after which they provide the required enrollment information and attest to their intent to enroll.

That means a single call can create more than one type of record. For example, one phone call may include:

1. A greeting and recording notice.
2. A Scope of Appointment discussion.
3. A plan-specific marketing or sales discussion.
4. A beneficiary decision.
5. A telephonic enrollment portion.

The marketing and sales portion may fall under the six-year CY2027 framework. The enrollment portion may need to be handled under the separate enrollment-record retention track. That is why agents should not think of retention as “one call, one rule.” A better approach is one file, multiple record types.

What about older recordings already being stored?

CMS stated that the revised marketing and sales call retention requirement would also apply to currently retained call recordings, meaning marketing and sales portions of calls older than six years would no longer need to be retained for that purpose.

But agents should be careful before deleting anything. Before removing older recordings, review whether the file includes an enrollment portion, whether your carrier or agency requires a longer period, whether a complaint or audit is pending, whether state law or contract obligations apply, and whether the record is tied to another compliance file. The safer practical approach is to classify records before making deletion decisions.

The issue is not just “Can I delete old audio?” The better question is: Do I know what this record is, why I kept it, and whether another rule still applies?

Why the 10-year misconception creates risk

The old 10-year shorthand creates two different problems.

First, some agents may overstore every audio file for 10 years without thinking about record type, storage cost, exportability, or data exposure. CMS itself recognized that audio files are large and that long-term storage can be burdensome.

Second, other agents may hear “10 years is gone” and assume they can relax their process. That is also wrong. The call recording requirement still exists for marketing and sales calls, and enrollment records remain separate.

Independent agents are still included

Some commenters suggested that call recording requirements should apply to call centers but not independent agents. CMS rejected that approach and stated that all sales and marketing calls should be recorded, not just those from call centers, because complaints involve both independent agents and call-center agents.

For independent Medicare agents, the takeaway is straightforward: being a solo agent or small agency does not remove the need for a clean recordkeeping workflow.

In fact, independent agents often need better record control because their files may be scattered across a personal phone, CRM, FMO portal, carrier system, email inbox, e-signature tool, desktop folder, and cloud drive. When a record is needed, the problem is rarely that the agent never saved anything. The problem is that the agent cannot quickly find the right version of the right record.

Why Business Line + Vault fits the new retention reality

The CY2027 change makes one thing clear: Medicare agents need more than a call recorder. They need a recordkeeping system that can organize different types of compliance records.

Business Line + Vault gives licensed Medicare and ACA agents a dedicated recorded business line with automatic call recording and secure vault storage. The platform is designed to help agents handle insurance sales calls, capture call recordings, send electronic Scope of Appointment forms, support telephone SOA and voice-signature workflows, store ACA consumer consent and eligibility review tools, store telephonic enrollment-related records, upload sales documents, and export records if the agent changes FMOs, agencies, CRMs, phone systems, or sales workflows.

That matters because the new CMS framework is not just about time. It is about classification.

A strong agent workflow should help answer:

• Is this a marketing/sales call?
• Is there an enrollment portion?
• Is there an SOA connected to the call?
• Is there a telephone SOA or voice authorization?
• Are there ACA consent or eligibility review documents?
• Are supporting documents stored with the same file?
• Can the agent retrieve or export the record later?

Business Line + Vault is built around that practical recordkeeping problem. The call lives with the file instead of floating separately in a phone dashboard.

Generic phone recording is not the same as compliance recordkeeping

A regular VoIP system may record calls, but most phone systems are built around communications, not insurance compliance files.

That distinction matters. A generic phone system may show a call date, phone number, duration, and audio file. But a Medicare compliance file may also need the SOA, disclosure evidence, sales notes, plan-related documents, enrollment-related call record, ACA records, uploaded files, and exportable audit packet.

Business Line + Vault is designed to keep recordings, electronic forms, and documents together. Agents can store call recordings, SOAs, ACA consent records, eligibility review documentation, telephonic enrollment records, uploaded files, and supporting sales documents in one vault.

The goal is not just to prove that a call happened. The goal is to preserve the evidence of what happened.

A practical retention workflow for Medicare agents

1. Record the applicable Medicare marketing and sales calls

Do not interpret the six-year retention change as the end of call recording. CMS’s final rule states that marketing and sales calls must be recorded and retained in their entirety for at least six years.

2. Keep audio for the first three years

During the first three years, keep the actual audio. Do not substitute a summary or transcript for the required audio period.

3. Decide whether to keep audio or transcripts for years four through six

After year three, decide whether your workflow will keep audio or maintain complete and accurate transcripts. If you use transcripts, make sure they are full transcripts, not summaries.

4. Tag enrollment records separately

Enrollment records are not simply “marketing call recordings.” If the call includes a phone enrollment portion, that portion may serve as the enrollment form and proof of intent. Keep it on the separate enrollment-record retention track.

5. Store the related records together

A call recording without the SOA, enrollment context, notes, and documents may be hard to use later. Store the record as a file, not as disconnected fragments.

6. Keep exportability in mind

Agents change systems. They change FMOs. They change CRMs. They change phone tools. A good compliance archive should not trap the agent’s records inside a workflow the agent may stop using.

What agents should not do

Agents should avoid three common mistakes.

Mistake one: assuming all Medicare call recordings still require 10 years of audio storage. That is no longer the best universal explanation for marketing and sales calls under the CY2027 framework.

Mistake two: assuming the 10-year rule disappeared completely. Enrollment records remain separate, and phone enrollment records should be handled carefully.

Mistake three: relying on scattered storage. A recording in one system, SOA in another, notes in a CRM, and enrollment evidence somewhere else creates a retrieval problem. The record may technically exist, but it may not be usable when needed.

Where Vault Only can help after AEP

The retention issue does not end when AEP ends.

Many agents need a full recorded business line during busy selling seasons, but they may not need every active selling tool year-round. Business Line + Vault includes a Vault Only option for agents who want lower-cost off-season storage or who do not need the recorded business line active all year. The Business Line + Vault pricing section lists the core Business Line + Vault offer at $39.99/month and Vault Only at $9.99/month for continued access to stored records, stored call recordings, stored SOAs and ACA records, uploaded documents, and record export.

That is a practical fit for Medicare agents because retention is long-term, but selling activity is seasonal. You may not need the same call volume in February that you need during AEP, but you still need access to the records.

The bottom line

Medicare agents should stop using “10 years” as a one-size-fits-all answer for call recordings.

For CY2027, Medicare marketing and sales call recordings move to a six-year retention framework: audio for years one through three, then audio or a complete and accurate transcript for years four through six. But enrollment records remain separate, and phone enrollment portions of calls still require careful long-term handling.

The best compliance workflow is not just to record calls. It is to classify the record, store it with the related SOA and sales documents, preserve the enrollment file where applicable, and keep everything retrievable.

That is what Business Line + Vault is built to support: a dedicated recorded business line and compliance vault for Medicare and ACA agents who need call recordings, SOAs, consent records, enrollment-related records, and sales documents in one organized place.

Sources

• Federal Register, 91 FR 17384: Contract Year 2027 Medicare Advantage and Part D final rule.
• Business Line + Vault: Informed + Choice product page for the recorded business line and compliance vault workflow.

Frequently Asked Questions

Do Medicare agents still need to keep call recordings for 10 years?

Not as a universal rule for every Medicare marketing or sales call recording. Under the CY2027 final rule, marketing and sales call recordings must be retained for at least six years. Audio is required for the first three years, and audio or a complete and accurate transcript may be used for years four through six. Enrollment records remain on a separate 10-year retention track.

Did CMS eliminate Medicare call recording?

No. CMS did not eliminate Medicare call recording. CMS stated that all marketing and sales calls, including the audio portion of calls conducted through web-based technology, must be recorded and retained in their entirety for at least six years.

When can Medicare agents use transcripts instead of audio?

For marketing and sales call records, transcripts may be used during years four, five, and six of the six-year retention period. For the first three years, records must be maintained in audio format.

What counts as a complete and accurate transcript?

CMS says a complete and accurate transcript documents the full recording and reflects all statements made by the participants as they originally occurred. A call summary, CRM note, or short AI recap is not the same thing as a complete transcript.

Do enrollment records still need to be kept for 10 years?

Yes. CMS stated that the CY2027 marketing and sales call retention change maintains the separate 10-year requirement for enrollment records. CMS also explained that, for phone enrollments, the enrollment portion of the call can serve as the enrollment form and proof of the beneficiary intent to enroll.

What if one call includes both sales discussion and enrollment?

Treat the call carefully because it may contain different record types. The marketing or sales portion may fall under the six-year framework, while the enrollment portion may need to be retained as an enrollment record. A practical workflow is to tag, segment, or otherwise identify the enrollment portion and store it with the related enrollment file.

Can independent agents ignore call recording if they are not in a call center?

No. CMS rejected the idea of applying the recording requirement only to call centers. CMS stated that all sales and marketing calls should be recorded because complaints involve both independent agents and call-center agents.

Can agents delete marketing and sales recordings older than six years?

CMS stated that the revised retention requirement would apply to currently retained marketing and sales call recordings, meaning marketing and sales portions older than six years would no longer need to be retained for that purpose. Agents should still review whether another retention rule, complaint, audit, carrier rule, agency rule, or enrollment-record requirement applies before deleting records.

Is a regular business phone system enough?

A regular phone system may record calls, but Medicare agents usually need more than audio files. They need a way to keep recordings, SOAs, enrollment-related records, ACA consent records, notes, and supporting documents organized and retrievable. Business Line + Vault is built for that insurance-agent recordkeeping workflow.