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So, go back and ask Brandon how getting an SOA while you're there and then calling them is compliant? His "Better safe than sorry" doesn't make a lick of sense! If one is not compliant, then neither is his suggestion!
Either you know the rules and how to play them, or you don't. Seems he doesn't understand the rules 100% either.
Ha - I'm sure his knowledge of CMS is on point.
The items you mentioned above were my words - not his.
Best to be cautious and follow the rules.