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From Aetna communication today:
Are call centers exempt from the SOA requirements because the calls are not considered personal meeting appointments?
Call centers are not exempt from the SOA 48-hour rule.
Does the SOA 48-hour rule apply to telephonic and electronic interactions?
Yes, it does. Telephonic and electronic communications are not exempt from the SOA 48-hour rule. The rule applies to any personal marketing appointment, whether in person, telephonic or virtual/electronic.
However, in addition to the exceptions outlined in the Final Rule and noted in the previous question, CMS has clarified that the 48-hour rule is not applicable to inbound calls. TPMOs should still obtain a SOA for inbound sales/marketing calls and electronic communications, but the 48-hour guideline does not apply to these scenarios.
How does the SOA 48-hour rule work relative to outbound calls?
The SOA 48-hour rule does apply to outbound calls even if the beneficiary has requested a call to discuss plans. The initial outbound call is to determine the type of plans the member would like information on and to schedule the sales call at least 48 hour after this contact.
Does the SOA 48-hour rule apply to contracted agents that receive live transfer calls?
CMS clarified that the 48-hour rule is not applicable to inbound calls. If the initial outreach to a beneficiary is conducted as an outbound call and then transferred to an agent, this is still considered an outbound call and the 48-hour rules apply. The agent should not discuss plans after this live transfer, but rather schedule an appointment at least 48 hours after the SOA is agreed to by the beneficiary.
Is there an issue with agents taking calls and doing immediate enrollments without the 48-hour waiting period?
As long as it is a member-initiated inbound call, the SOA 48-hour rule does not apply and agents may conduct marketing, sales and enrollment activities during that inbound call, but it must be recorded.
Are call centers exempt from the SOA requirements because the calls are not considered personal meeting appointments?
Call centers are not exempt from the SOA 48-hour rule.
Does the SOA 48-hour rule apply to telephonic and electronic interactions?
Yes, it does. Telephonic and electronic communications are not exempt from the SOA 48-hour rule. The rule applies to any personal marketing appointment, whether in person, telephonic or virtual/electronic.
However, in addition to the exceptions outlined in the Final Rule and noted in the previous question, CMS has clarified that the 48-hour rule is not applicable to inbound calls. TPMOs should still obtain a SOA for inbound sales/marketing calls and electronic communications, but the 48-hour guideline does not apply to these scenarios.
How does the SOA 48-hour rule work relative to outbound calls?
The SOA 48-hour rule does apply to outbound calls even if the beneficiary has requested a call to discuss plans. The initial outbound call is to determine the type of plans the member would like information on and to schedule the sales call at least 48 hour after this contact.
Does the SOA 48-hour rule apply to contracted agents that receive live transfer calls?
CMS clarified that the 48-hour rule is not applicable to inbound calls. If the initial outreach to a beneficiary is conducted as an outbound call and then transferred to an agent, this is still considered an outbound call and the 48-hour rules apply. The agent should not discuss plans after this live transfer, but rather schedule an appointment at least 48 hours after the SOA is agreed to by the beneficiary.
Is there an issue with agents taking calls and doing immediate enrollments without the 48-hour waiting period?
As long as it is a member-initiated inbound call, the SOA 48-hour rule does not apply and agents may conduct marketing, sales and enrollment activities during that inbound call, but it must be recorded.
How bout put a sign on the table that has the disclaimer and a sign that says " agents Xs office" with office hours and call it good. 
being facetious I mean it's a requirement to post office hours, so sounds good to me.
