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Clarification & Changes to Call Recording Requirements in the 2024 CMS Final Rule: What Insurance Agencies Need to Know

2024 CMS Final Rule changes for call recording requirements

Last year we wrote an article about the Centers for Medicare & Medicaid Services (CMS) ruling requiring that all calls marketing Medicare and Medicaid be recorded and stored. That ruling was set to go into effect on October 1st, 2022. You can read that article about the May 2022 CMS Ruling here.

On April 5th, 2023 the CMS released the Final Rule for Contract Year (CY) 2024 which will take effect on September 30th, 2023. While Intulse would not normally report on a CMS ruling, this new Final Rule has an impact on call recording requirements, clarifying which calls specifically must be recorded and which do not need to be recorded and stored.

An Overview of the 2024 CMS Final Rule

As we said, in early April 2023 CMS published the Final Rule for Contract Year 2024. While the ruling covers many topics, like appointment scopes, disclaimers for third-party marketing organizations, usages for the Medicare name (copyrighted and trademarked materials), changes to the items discussed when choosing prescription plans, and the most important to Intulse: clarification on which client calls that the CMS requires be recorded.

CMS Call Recording Requirement Clarifications

The previous recording requirement applied to all field agents and insurance professionals who enroll beneficiaries into new plans, whether they are current or new clients. The wording of the rule referenced “marketing” calls, but NAHU confirmed that CMS interpreted “enrollment” as “marketing.” This meant that agents had to assume enrollment and marketing were one and the same in the previous ruling’s language.

However, the 2024 CMS Final Ruling clarifies this statement and makes it clear that the only calls that must be recorded in their entirety are limited to marketing, sales, and enrollment calls. Client calls for event invitations (webinars, seminars, etc…), verification that clients have received their ID cards, and calls to schedule appointments are not required to be recorded.

How Does the CMS Ruling Affect Insurance Agencies?

Well, agencies will still be required to record and store certain calls. Intulse does make this far easier as call recording is a standard feature of our VoIP phone system. If you’re an Intulse client, we have good news! Meeting this requirement is relatively easy. Call recording is a feature you already have access to and doesn’t cost you anything to enable, even on your mobile devices. You may incur call recording storage fees, but they are very affordable.

You can choose to start/stop recording any call you’re actively on from the My Phone screen in the Intulse Mobile App. Or, you can contact our support team to have automatic call recording turned on for all incoming and/or outgoing calls.

What Other Benefits Can Intulse VoIP Offer Insurance Agencies?

Beyond our standard VoIP phone system features, insurance agencies can absolutely benefit from our native CRM integration with insurance industry CRMs like:

When combined with our standard feature set, VoIP integration with insurance CRMs unlocks a whole new world of automation by being able to link calls, client activities, recordings, and much more with your client’s records in the CRM directly from the Intulse VoIP phone system.

If you’re not a current Intulse client but need assistance with call recordings to ensure you’re following the updated requirements starting this year, we are here to help!

Contact our team today to learn more.