The National Association of Insurance and Financial Advisors (NAIFA) praised the release of the final Medicare Advantage and Part D rule (CMS-4212-P), which incorporates several of NAIFA’s core recommendations aimed at improving access to professional guidance while reducing unnecessary administrative burdens on agents and brokers.
NAIFA submitted a comprehensive comment letter earlier this year, highlighting practical, beneficiary-centered solutions drawn from real-world advisor experience. The final rule reflects meaningful progress across several priority areas, including scope of appointment (SOA) flexibility, call recording requirements, marketing event restrictions, and oversight of third-party marketing organizations (TPMOs).
“This final rule represents a thoughtful and balanced approach that recognizes the critical role agents and brokers play in helping seniors navigate complex Medicare decisions,” said NAIFA President Christopher L. Gandy, LACP. “We are encouraged to see CMS adopt several of NAIFA’s recommendations that will reduce unnecessary barriers, improve efficiency, and most importantly, ensure that beneficiaries continue to have access to trusted, professional advice.”
Key Highlights of the Final Rule Include:
- Greater Flexibility for Beneficiaries and Agents: CMS eliminated the 48-hour waiting period for Scope of Appointment, allowing same-day consultations and improving timely access to coverage decisions.
- Reduced Administrative Burdens: The rule shortens call recording retention requirements from 10 years to 6 years, a significant step toward easing compliance costs while maintaining oversight.
- Improved Access Through Event Flexibility: CMS removed the 12-hour restriction between educational and marketing events at the same location, making it easier for beneficiaries, especially those with mobility challenges, to access information and enrollment opportunities.
- Enhanced Oversight of Marketing Practices: Updates to TPMO disclaimer requirements improve transparency while aligning with NAIFA’s call for clearer, more practical regulatory standards.
- Streamlined Enrollment Processes: Changes to Special Enrollment Periods (SEPs) related to provider terminations simplify the process for beneficiaries while maintaining program integrity.
See further details on key NAIFA recommendations and the degree of inclusion in the final rule.
“NAIFA’s advocacy is rooted in real-world experience and a deep commitment to serving both financial professionals and the consumers who rely on them,” Gandy added. “These updates will help ensure a more efficient, accessible, and sustainable Medicare marketplace.”
NAIFA’s Medicare Collective played a key role in shaping the organization’s recommendations, leveraging frontline insights to inform policy that supports both consumer protection and professional guidance.

