Medicare Educational Events vs Marketing Events: CY2027

A Medicare educational event is a group session, advertised as educational, that informs people about Medicare in general. A marketing event is a sales event where you may present specific plans and take applications. Under 42 CFR 422.2264(c), you can't market specific Medicare Advantage plans or accept applications at an educational event. For CY2027 marketing beginning October 1, 2026, CMS also lets a marketing event directly follow an educational event, lets you collect Scope of Appointment forms at educational events, and drops the 48-hour SOA wait.

This guide covers what you may and may not do at each event type, the SOA and sign-in sheet rules, gifts and meals, follow-up after the event, and a step-by-step plan for a compliant seminar.

Key takeaways

• Educational events must be advertised as educational. At them you may not market specific MA plans or benefits, give sales presentations, or distribute or accept applications.
• At an educational event you may hand out communications materials and business cards, answer questions beneficiaries raise about MA plans, and collect business reply cards (BRCs) and SOA forms.
• Marketing events allow sales presentations, marketing materials, applications, and SOA collection. You can't require a sign-in sheet, run health screenings, or serve meals.
• The CY 2027 final rule took effect June 1, 2026, but its marketing changes apply to CY2027 marketing beginning October 1, 2026.
• A marketing event may directly follow an educational event if you announce the switch and give people a sufficient opportunity to leave.
• After a sales event, don't call attendees unless they gave express permission or asked to be contacted. Carriers may keep stricter rules than CMS.

What's the difference between a Medicare educational event and a marketing event?

42 CFR 422.2264(c) recognizes three settings for meeting beneficiaries: educational events, marketing or sales events, and personal marketing appointments. Each can be held face to face or virtually, so the same rules cover webinars.

Educational event

An educational event must be advertised as educational and designed to generally inform beneficiaries about Medicare, including Medicare Advantage, prescription drug programs, or any other Medicare program. You may not market specific MA plans or benefits there.

Marketing or sales event

A marketing or sales event is a group event that falls within the regulatory definition of marketing in 422.2260. Here you may present plans and take applications.

Personal marketing appointment

A personal marketing appointment is tailored to an individual or a small group, such as a married couple. It isn't defined by location, so a kitchen table, your office, a phone call, or a quiet corner after a seminar can all be personal marketing appointments.

What counts as marketing?

Under 422.2260, marketing means materials or activities that meet both an intent standard and a content standard. Content about benefits, premiums, cost sharing, or Star Ratings is the kind of content that can make an activity marketing. The same section defines a third-party marketing organization (TPMO) to include independent agents and brokers compensated for lead generation, marketing, sales, and enrollment in the chain of enrollment. If you sell MA or Part D plans, assume the TPMO rules apply to you.

What can you do at each event type?

Sources: 42 CFR 422.2263 and 422.2264 and the 2022 Medicare Communications and Marketing Guidelines.

What changed for CY 2027, and when did it take effect?

Both dates you've seen are correct, but they cover different things. The CY 2027 final rule (CMS-4208-F3 and CMS-4212-F) says its regulations are effective June 1, 2026, apply to coverage beginning January 1, 2027, and that its new marketing and communications policies apply to all contract year 2027 marketing beginning October 1, 2026.

CMS's September 2026 Partner Tip Sheet (CMS Product No. 12237-P) sums up the event changes for CY2027 materials beginning October 1, 2026. Plans may now:

• Hold marketing events directly following educational events in the same location, if people are notified and given the opportunity to leave
• Schedule personal marketing appointments any time after an SOA is completed
• Collect SOA forms at educational events

Two related changes affect your sales calls. According to CMS's CY 2027 presentation, the TPMO disclaimer no longer lists SHIPs and must be given verbally before benefits are discussed, instead of within the first minute of a call. Plans must also keep sales and marketing call recordings for 6 years, down from 10, and may use transcripts in place of recordings for years 4 to 6.

Can a marketing event follow an educational event right away?

Yes, with conditions. Under 422.2264(c)(2)(i), when a marketing event directly follows an educational event, you must:

1. Tell beneficiaries that the educational event is ending and a marketing event will begin shortly.
2. Give them a sufficient opportunity to leave before the marketing event starts.

The 2022 MCMG adds that you must make it clear when an encounter moves from communications to marketing, and that all requirements for each activity type apply during that portion. Advertise the educational part as educational, and run the marketing part under every marketing rule.

A transition script you can adapt

This wording is advice. Run it past your carriers before you use it.

"That wraps up the educational part of today's session. In a few minutes, I'll begin a separate sales presentation about specific Medicare Advantage plans that I represent. You don't need to stay for it, and you don't need to give me any information to leave. If you'd like to go, now is a good time, and thank you for coming. We'll take a short break and start the sales presentation at [time]."

Then actually pause. Keep the exit clear, don't stand at the door collecting names, and don't start until people who want to leave have left. If you stay with someone afterward for a one-on-one review, that's a personal marketing appointment and needs an SOA first.

What are the Scope of Appointment rules at and after events?

An SOA is still required. Under 422.2264(c)(3), you must agree upon and record the scope before a personal marketing appointment, and the SOA must be in writing for in-person appointments.

The final rule removed the 48-hour waiting period and its two exceptions, the last four days of an election period and beneficiary walk-ins. An SOA is still required, just without a set timeframe.

The 2022 MCMG says an SOA must be documented before the appointment for all marketing activities, including walk-ins, by one of these methods:

• Signed hard copy
• Telephonic recording, for phone appointments only
• Electronic signature

It must include the product types to be discussed, the appointment date, beneficiary and agent contact information, and a statement that there's no obligation to enroll. If the conversation turns to a different plan type, you need a new SOA. For more, see our guide to Medicare scope of appointment rules.

Can you use a sign-in sheet at a Medicare seminar?

At a marketing event, you can't require one. Under 422.2264(c)(2)(iii), you may not require sign-in sheets or require attendees to provide contact information as a prerequisite for attending. You also may not run health screenings, health surveys, or other activities that could be viewed as cherry-picking, and you may not use information collected for raffles or drawings for any other purpose.

As practical advice, treat any sign-in sheet as optional at every event type:

• Label it "Optional" in large print.
• Keep it away from the entrance so no one feels it's a ticket in.
• Use a separate raffle slip that you discard after the drawing.
• Offer BRCs or SOA forms to people who want follow-up.

What are the gift, meal, and raffle limits?

Under 422.2263(b), plans may not provide meals to potential enrollees in marketing, regardless of value. Gifts must be of nominal value as governed by HHS OIG guidance, offered to similarly situated beneficiaries regardless of enrollment, and not given as cash or monetary rebates.

The 2022 MCMG, dated 02/09/2022, states OIG's then-current interpretation of nominal value as no more than $15 per item or $75 in the aggregate, per person, per year. It also says nominal gifts may not be cash or cash equivalents, such as a general Visa gift card. Confirm the current OIG figure and your carriers' limits before you buy anything.

On food, the same guidelines say refreshments and light snacks are not meals, as long as they aren't bundled into a meal. Meals may be provided at educational events that meet CMS's regulations. When a marketing event follows the educational part, a cautious choice (advice) is to serve only refreshments so the marketing portion never includes a meal.

If you offer a drawing, prizes, or a free gift, 423.2267(e)(38) requires a promotional give-away disclaimer making clear there's no obligation to enroll.

How should you advertise a Medicare seminar?

Your invitation decides what kind of event you can hold. An educational event must be advertised as educational, so don't mention specific plans or benefits in its ads.

Required content:

• Accommodations disclaimer. Under 423.2267(e)(36), every advertisement or invitation to any event in 423.2264(c) must say that accommodations for persons with special needs are available, with a phone and TTY number.
• TPMO disclaimer. Under 423.2267(e)(41), a TPMO that doesn't sell for all Part D sponsors in the service area must use the standardized disclaimer beginning "We do not offer every plan available in your area," state the number of organizations and plans represented, and refer people to Medicare.gov or 1-800-MEDICARE. It goes in TPMO marketing materials.
• Give-away disclaimer if you advertise a drawing or gift.

The facts CMS publishes don't set one event reporting process for agents, and the 2022 MCMG lets plans add their own restrictions. Ask each carrier and your upline whether they require event registration, material review, or advance notice, and follow the strictest one.

Can you call people who attended your seminar?

Only with permission. Under 422.2264(a)(2)(iv)(C), calls to beneficiaries who attended a sales event are prohibited unsolicited contact unless the beneficiary gave express permission to be contacted. Under 422.2264(a)(3), returning a call or calling someone who completed a BRC requesting contact is not unsolicited.

The same section bans unsolicited door-to-door solicitation, approaching people in common areas such as parking lots, hallways, and lobbies, social media direct messages, and unsolicited cold calls, robocalls, texts, or voicemails, including calls based on referrals. Don't work the parking lot after a seminar, and don't call an attendee's friend because the attendee mentioned them.

When you do call, give the TPMO disclaimer verbally before you discuss any benefits. CMS's Medicare rules aren't the only ones that apply to calls and texts. Confirm consent and calling-time rules with your compliance team. For wording ideas, see our insurance follow-up text templates.

Can your carriers and FMO be stricter than CMS?

Yes. The 2022 MCMG says plans may impose additional restrictions on downstream entities as long as they don't conflict with CMS rules. A carrier could keep a waiting period after the SOA, bar SOA collection at educational events, or require events to be registered in advance. Before your first CY2027 seminar, read each carrier's current agent guide and ask your upline which rules govern your contracts.

How do you plan a compliant Medicare seminar?

These steps are advice built on the rules above.

1. Pick the event type. Educational only, marketing only, or educational followed by marketing. Write down why.
2. Check dates. Marketing of 2027 plans starts October 1, 2026, and applications for a January 1 effective date wait until October 15 unless the beneficiary has an SEP. See our Medicare enrollment periods cheat sheet.
3. Write the invitation. Label educational events as educational, and add the accommodations disclaimer, the TPMO disclaimer where required, and a give-away disclaimer if you offer a prize.
4. Get carrier sign-off on materials and register the event if your carriers require it.
5. Prepare materials. Separate educational handouts from marketing materials, and bring blank SOA forms, BRCs, an optional sign-in sheet, and, for a marketing event, applications.
6. Run the educational part without plan-specific pitches, answering only the plan questions people raise.
7. Make the transition with the script, a real pause, and a clear exit.
8. Run the marketing part. Give the TPMO disclaimer before discussing benefits (advice), and skip health questions.
9. Collect SOAs and BRCs. Get a written SOA before any in-person one-on-one review.
10. Document and follow up only with people who gave permission or asked you to contact them.

What should you document, and how long should you keep it?

Checklist (advice):

• Final invitations and ads, with the dates they ran and any carrier approval
• The event agenda, showing where the educational part ended and marketing began
• Optional sign-in sheets, if anyone signed
• Signed SOAs, with product types and appointment dates
• BRCs and written permission to contact
• Raffle slips, discarded after the drawing
• Call recordings or transcripts from follow-up sales calls

Plans must keep sales and marketing call recordings for 6 years, with transcripts allowed for years 4 to 6. That duty sits with plans, so ask your carriers how long they expect you to keep recordings, SOAs, and BRCs.

Edge cases: webinars, client events, LTC facilities, Medigap and ACA

• Webinars and Zoom events. 422.2264(c) covers events held virtually, so the same educational and marketing rules apply.
• Events for existing clients. Apply the intent and content test from 422.2260. If you'll discuss benefits, premiums, cost sharing, or Star Ratings, treat the event as marketing and ask your carriers how they classify client events.
• Long-term care facilities. Under 422.2264(c)(1)(iv), you may schedule appointments with residents only at the resident's request. A visit the resident didn't request is prohibited unsolicited door-to-door marketing.
• Early October. You may market from October 1, but hold applications for January 1 coverage until October 15 unless the beneficiary has an SEP.
• Medigap and ACA seminars. The rules in this guide are the MA and Part D communication rules in Parts 422 and 423. For Medigap or Marketplace events, ask your state insurance department and your carriers what applies.

Common mistakes and outdated advice

• Waiting a set number of hours between the educational and marketing parts. CMS dropped that gap for CY2027 marketing, though a carrier may keep it.
• Refusing SOAs at educational events. They're now allowed under CMS rules, unless your carrier says otherwise.
• Holding to the 48-hour SOA wait as a CMS rule. It's gone, but the SOA itself isn't.
• Advertising "lunch and learn" for an event that turns into a sales pitch.
• Starting the marketing presentation without a real pause.
• Requiring names at the door.
• Calling sales event attendees who never gave permission.
• Giving the TPMO disclaimer in the first minute of the call and then never again before benefits.

Keeping event leads organized in LeadGPT

When an attendee gives written permission or returns a BRC, you can add them as a lead and attach the signed SOA or BRC to the lead record, using a custom field to note the permission date. Calls you make or answer in LeadGPT are recorded, with a transcript and AI summary in the Call Log that you can play or download for your own archive. Recording is always on with no announcement, so confirm disclosure requirements with your compliance team. See the features overview or the interactive demo.

What to do next

1. Rewrite your seminar invitation template with the required disclaimers.
2. Add the transition script to your presentation notes.
3. Ask each carrier for its CY2027 event and SOA rules in writing.
4. Review our Medicare marketing guidelines for agents and AEP preparation checklist.

This guide is general information, not legal or compliance advice. Confirm each rule with CMS, your carriers or upline, and your compliance team. You'll find more guides in our compliance category, and our editorial policy explains how we research them.