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Stay Compliant. Stay in Business.
Choosing a Lead Generation Partner? Read This First.
Shopping for a new lead generation company can be an exciting step toward growing your business. But as you expand your reach, it’s essential to protect yourself and your license.
While many vendors claim to be CMS compliant, true compliance goes beyond a simple statement—it requires full transparency between the lead company’s marketing practices and you, the agent receiving the beneficiary’s information.
⚠️ What You Need to Know
As the licensed writing agent, you are ultimately responsible for the marketing that generated your leads. That includes the advertisement, consumer consent, and any recordings tied to the interaction.
If a compliance issue arises, the carrier will not look to your lead vendor—they will look to you.
In the event of an allegation, you may be required to quickly provide:
The exact advertisement, flier, or Business Reply Card (BRC)
Radio or TV scripts
Proof of consumer consent
Call recordings tied to the interaction
If your lead vendor cannot provide this documentation, your license—and your business—could be at risk.
Protect Yourself with the Lead Vendor Checklist
Before committing to any lead provider, make sure you get clear, transparent answers to these six critical questions:
1. Operations Location
Where are your operations based? Are they located in the United States or offshore?
2. Marketing Channels
How are leads generated? (Direct mail, digital advertising, social media, TV, or radio?)
3. Allegation Support & Evidence
Can you provide a copy of the exact ad, flier, or BRC used to generate my leads if needed for a compliance review?
4. Consent to Contact (C2C)
Will I receive a signed or timestamped Consent to Contact form with every lead?
5. Compliant Recordings
Do you provide recordings for TPMO disclaimers and Scope of Appointment (SOA), if applicable?
6. Live Transfer Verification
Do prospects speak with a live representative before being transferred? If so, can I review the exact script being used?
The Bottom Line
A reputable lead generation company should have no hesitation in answering these questions clearly and completely.
Protect your clients. Protect your license. Protect your business.
And if you ever need support vetting a vendor, don’t hesitate to reach out—we’re here to help.
COMPLIANCE FAQs
Yes, it is best to have your compliance team tell you how you cannot do your job, while telling you a compliant way to do your job, rather than a carrier spotting something and telling you to take down or destroy all the material you created. Yes, agents before you have had to throw out hundreds of dollars to recreate compliant material. Let us look at it first.
This depends on the material. If the material is communications, we still like to have it reviewed to be sure all the FCC and CMS disclaimers are on the material. If it is truly “communications”, we will add a “C” to the SMID and send it back for use.
If the material involves any type of “marketing”, which is a very broad definition with CMS, then we will add an “M” to the SMID and file it with HPMS on your behalf for the carriers to opt in and be aware of the piece. NOTE: Even if your material does not include benefits or costs, it could still fall under “marketing” so always send it to our team so we can keep you compliant.
You must put that you are: (either will be acceptable)
Licensed Sales Agent
Independent Sales Agent
Local Licensed Sales Agent
Local Independent Sales Agent
Not affiliated or endorsed by CMS or other entity
You may be connected to a licensed sales agent by calling this number (not on biz cards)
Near your phone number, you MUST have TTY 711. This is the state relay service for those who are hearing impaired. The caller will call TTY 711 and an interpreter will call you. (123-456-7890 TTY 711)
Yes, if it is not used in a manner that won’t cause confusion, misunderstanding, or misrepresentation. ANY material that is created with the Medicare Card image will need to be submitted to CMS for oversight. Our team will send this on your behalf. Once reviewed by CMS, you will receive an email that you must keep in the event a carrier asks.
A VERY generic website, Facebook, or other social media page is recommended. You will not be allowed to list carrier names, logos, benefits, or costs on your pages without carrier approval.
If you have any of these, you will need to send us your handles. It is much better to be transparent than to be found by the carrier and told to remove your pages.
Marketing for AEP begins on October 1st and enrollment begins on October 15th. This means that you can begin sharing, talking, and promoting January 1st effective plans as early as 10/01/2026 at 12:01 AM! All the 2027 Final Rules will take effect at that time as well. Remember, NEVER accept an enrollment before 10/15/2026 11:59 PM!
You can! In fact, we have an attestation just for this. First, create your material in English and send it to our team for review along with the attestation. (This is a promise that the translated material will not be altered, from the approved English version except for the language). After our team reviews it and all corrections are made, (if any) the material will be stamped as approved and you will be able to make the translations. Lastly, you will send us a copy of the final piece.
No, you must record all parts of the call that pertain to the “Chain of Enrollment”. This means any part of the conversation where the beneficiary is made aware of Medicare Advantage plans or Medicare Prescription Drug plans. The recorded call must be securely kept for a minimum of three years and an accurate transcription of the call must be kept for the remaining three years. This totals six years for all marketing calls. We strongly recommend that you use Medicare Center!!
Chain of Enrollment includes
Inbound or Outbound call for an appointment to review plans
Inbound or Outbound call for asking about doctors, hospitals, pharmacies, medications in a plan
Inbound or Outbound call asking about the benefits or highlights about a plan
Inbound or Outbound call following up on an SOA or BRC
Basically – any call that could lead into a conversation about benefits, appointments, or an enrollment
The enrollment audio call MUST be retained for a minimum of ten years.
Confirming an appointment time that was already set and recorded
Beneficiary asking for the carrier’s customer service number after enrollment
Beneficiary asking when their kit/card will arrive after enrollment
Sometimes they do, but after being in the industry for nearly fifteen years, we found that people like to hear about ALL the plans in their area instead of being steered to one. The return rate for branded products is exceptionally low.
Can You?
Some carriers will allow an agent to use their goods AFTER the agent signs agreements. Before taking this long approach, check with each carrier you represent, most will have ready-to-go approved material for independent agent use with no review time required.
We strongly recommend completing a digitally recorded SOA through Medicare Center or carrier provided platform for retention requirements. IF you must have a paper scope, you can print the one below.
IntegrityCONNECT also has a SOA that you can send your contact.
Well, we have enrollment periods to work by and carrier deadlines to work by. If you are wanting something to be approved for AEP, I would get that in by the first week of July. Any time after that may be approved by mid-October due to the volume carriers receive. If it is ONLY communication material, it may be pushed through sooner.
All other material can be sent anytime
It is our specialty. Most carriers will alert us or copy us on the allegation email thread, but sometimes the don’t. Regardless, we are here to assist.
No, that would be our other teams
HART@trustedseniorspecialists.com HART (Helpful Agent Resource Team)
Compliance@trustedseniorspecialists.com
Your team,
Sondra Ford-Leontoudis, Evelyn Lira, Anna Amassiadis