Medicare and ACA call center scripts: openings, fronter transfers and a QA checklist
Every Medicare or ACA call opening carries four things: who is calling and for which company, a notice that the call is recorded, the TPMO disclaimer before any benefits are discussed on a Medicare sales call, and a plain purpose. On an AI-handled call, the AI says it is an AI first. Nothing may suggest the caller reached the government.
Use these as templates. Your compliance team approves the final script. Not legal advice.
Opening for a Medicare inbound call
A Medicare call center script has to do three jobs in its first thirty seconds: say who is calling, say the call is recorded, and give the TPMO disclaimer. Since the Contract Year 2027 rule, the disclaimer must be spoken on a sales call before any benefits are discussed, which replaced the old first-minute timing (42 CFR 422.2267(e)(41)(ii)). Putting it in the opening means it is never late. The wording below is quoted from 42 CFR 422.2267(e)(41), for a TPMO that does not sell every plan in the caller's area. Fill the brackets with your real counts.
"Thank you for calling [Agency name], this is Dana. This call is recorded for quality and compliance."
"We do not offer every plan available in your area. Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options."
"[Agency name] is a licensed insurance agency, not Medicare. I can take a few details and connect you with a licensed agent. May I start with your ZIP code?"
If you represent every organization in the area, the rule gives a second version: "Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. You can always contact Medicare.gov or 1-800-MEDICARE for help with plan choices." The disclaimer no longer names SHIP, so retire any older script that still does.
Two lines to keep out of every opening: anything that claims you are recommended or endorsed by CMS or Medicare, and any use of the Medicare name or card that could mislead (42 CFR 422.2262(a)(1)(ix) and (xvii)). Marketing and sales calls must be recorded in full and kept for at least six years (the enrollment portion of a call, ten years). Our guide to Medicare call recording requirements covers retention, transcripts and dates.
Opening for an AI-handled call
When an AI voice agent answers, it says so in its first sentence, then follows the same opening. Our AI agents say they are an AI at the start of every call, inbound and outbound. On outbound calls it is also the law's direction: the FCC has ruled that AI-generated voices are "artificial" voices under the TCPA (FCC 24-17), and an artificial voice message must state the identity of the business responsible for the call at the beginning (47 CFR 64.1200(b)(1)).
"You are speaking with an automated AI assistant at [Agency name], and this call may be recorded."
"We do not offer every plan available in your area. Currently we represent [insert number of organizations] organizations which offer [insert number of plans] products in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options."
"I can take a few details and connect you with a licensed agent. What ZIP code do you live in?"
Medicare sales calls are recorded in full, so many teams say "this call is recorded" rather than "may be". Either way, the AI does the fronter's job only: it never discusses plans or benefits. That is how our AI voice agent for Medicare agencies works: it answers, screens, and warm-transfers to your licensed agents.
Opening for an ACA call
An ACA call center script has no federal disclaimer to read, but it has two hard limits. Agents and brokers on the federal Marketplace must give consumers correct information and refrain from conduct that is misleading or coercive (45 CFR 155.220(j)(2)(i)). Saying plainly that you are not HealthCare.gov or the government is the simplest way to keep a call from misleading anyone. And before helping with an application, the licensed agent must obtain and document the consumer's consent (45 CFR 155.220(j)(2)(iii)).
"Thank you for calling [Agency name], this is Dana. We are a licensed health insurance agency, not HealthCare.gov or the government, and this call is recorded."
"I can take a few details and connect you with a licensed agent. Which state do you live in?"
The consent step belongs to the licensed agent after the transfer. The rule says the record must include the scope, purpose and duration of the consent, the date, the consumer's name, the name of the agent or agency, and a way to withdraw it. For enrollments for plan years ending before January 1, 2028, verbal confirmation captured in an audio recording is one listed example. For plan years beginning on or after January 1, 2028, consent must be collected on an HHS-approved consumer consent form. Either way, the documentation is kept for at least ten years. A template for the agent (for plan years before 2028):
"Before I help with your Marketplace application, I need your consent. You are giving [agent name] at [agency name] permission to help you apply for coverage and financial help for the [plan year] plan year, and to view and update your application for that purpose. This lasts until [end date], and you can withdraw it any time by calling [number]. Today is [date]. Do you agree?"
The agent also needs a current agreement with the Exchange, which requires registering with it before helping anyone enroll through it (45 CFR 155.220(d)). Busy season? See ACA call center answering for open enrollment.
Fronter screening questions, and what a fronter must never say
A Medicare fronter script for a call center is short on purpose. Agents and brokers who sell Medicare Advantage plans must be licensed and appointed under state law where the state requires it (42 CFR 422.2274(b)(1)). An unlicensed fronter's job is to qualify the caller and hand off, nothing more.
Questions a fronter can ask
- "What ZIP code do you live in?"
- "Do you have Medicare Part A and Part B today?" (ACA: "Do you have health coverage today?")
- "Is it all right if I connect you with a licensed agent now?"
- "What is the best number to reach you if we are disconnected?"
What a fronter never says
- Any plan name, benefit, premium, copay or quote.
- Anything about subsidies, tax credits or what the caller "qualifies for".
- "Your Medicare benefits have changed" or any line that sounds like a government notice.
- "You could get money back" or other benefit bait to keep the caller on the line.
If the caller asks about benefits, the fronter's answer is always the same: "That is a great question for the licensed agent. May I connect you now?"
Fronter to licensed agent transfer language
A warm transfer keeps the caller on the line while the fronter introduces them. Three steps: ask permission, brief the agent, introduce the caller.
To the caller: "I can connect you with Luis, a licensed agent who can enroll you in a new plan, right now. Is that all right?"
To the agent, caller on hold: "Luis, I have Mrs. Carter from ZIP 33021. She has Part A and Part B and asked about plans in her area. She agreed to the transfer."
Back to the caller: "Mrs. Carter, Luis is on the line and can take it from here. Thank you for calling [Agency name]."
The handoff summary repeats only what the caller said. No guesses about savings and no promises the licensed agent has to walk back. The licensed agent then repeats the recording notice if your policy calls for it, and gives the TPMO disclaimer before discussing any benefits if the fronter did not. If you need people to work this handoff, nearshore live call center agents are provided through Ad Nomina's partner call center.
Final expense variant
Final expense is life insurance, not a Medicare product, so the TPMO disclaimer does not apply unless the call turns to Medicare plans. A final expense call center script still opens with name, company and the recording notice, and the fronter leaves quoting and selling to licensed agents. On outbound telemarketing calls, the caller gives their own name, the name of the company they call for, and a number or address where it can be reached (47 CFR 64.1200(d)(4)).
"Hi, this is Dana with [Agency name], a licensed insurance agency. This call is recorded. You can reach us at [phone number]. You asked us about final expense coverage, and I'd like to connect you with a licensed agent who can answer your questions. Is now a good time?"
"Before I connect you: what state do you live in, and what is your age range?"
The fronter does not mention monthly cost, health questions or approval odds. Those belong to the licensed agent. For staffing this line, see final expense call center outsourcing.
Objection handling without pressure
A good objection answer is honest, short, and lets the caller say no. These examples use [Agency name] and an agent named Dana.
"Are you with Medicare?"
"No. [Agency name] is a licensed insurance agency. We are not Medicare or the government. For information on all of your options, you can contact Medicare.gov or 1-800-MEDICARE."
"Just tell me what it costs."
"I'm not able to quote, but the licensed agent can go through the plans and costs in your area with you. May I connect you now?"
"I'm happy with my plan."
"That's good to hear. There is no need to change anything. Would you like me to take you off our call list?"
"I don't want to be recorded."
"I understand. Our sales calls are recorded, so I can't continue on this call. You can reach Medicare.gov or 1-800-MEDICARE for information on all of your options."
"Stop calling me."
"I'm sorry for the trouble. I've noted your request so we will not call you again." Then the agent records the request in your do-not-call list before the next call.
QA checklist for the script
A script only works if agents say it. Score recorded calls against these twelve items, each with a pass or fail and the line from the call behind it.
- The agent gives their first name and the company name in the first sentence.
- The recording notice is given before any personal question.
- On an AI-handled call, the AI says it is an AI in its first sentence.
- The TPMO disclaimer is read word for word, with your real counts, before any benefits are discussed.
- Nothing in the call suggests the caller has reached Medicare, CMS, HealthCare.gov or the government.
- The fronter asks only screening questions: ZIP code, current coverage, age range or Medicare status.
- The fronter never names a plan, premium, benefit, subsidy or price.
- Before the transfer, the fronter says the caller is going to a licensed agent who can enroll them in a new plan, and the caller agrees out loud.
- The handoff summary to the licensed agent repeats only what the caller said.
- On ACA calls, the licensed agent records consent with scope, purpose, duration, date, both names and how to withdraw it.
- Objections are answered without pressure, and a "no" ends the pitch.
- The whole call is recorded and kept for the period your rules require.
We score recorded calls against a checklist like this one, written from your own script. Call center QA for insurance agencies runs from $95 per agent per month, with a free 10-call pilot.
Common script mistakes
An old disclaimer
Scripts still citing "the first minute" or naming SHIP predate the Contract Year 2027 rule, which applies to CY2027 marketing from October 1, 2026.
Counts that never change
The organization and product counts depend on the caller's area. A single hard-coded number is wrong for most callers.
Benefits before the disclaimer
A fronter who pitches the specifics of a dental or grocery benefit to draw the caller toward a plan has started a benefits discussion. CMS treats a bare mention differently, but the safe script keeps benefits out until after the disclaimer.
Government sound-alikes
"Medicare benefits department" or "the Marketplace helpline" as a greeting misleads callers about who they reached.
A transfer without permission
Cold-transferring a caller who never agreed to it starts the licensed agent's call with a complaint.
For call centers and BPOs
If you run Medicare, ACA or final expense lines, the Ad Nomina partner program lets you offer your clients AI voice agents that answer and screen calls and call quality monitoring that scores recorded calls against the script. Where a client needs live agents to front and transfer, they are provided through Ad Nomina's partner call center. See our AI voice agent compliance standards for how the AI handles disclosure and recording.
Questions about Medicare and ACA scripts
What must a Medicare call script include?
A Medicare sales script needs a clear name and company, a recording notice, the TPMO disclaimer before any benefits are discussed, and a plain purpose for the call. It must not claim CMS or Medicare endorsement, and only licensed agents discuss plans. Recording itself is a plan contract duty under 42 CFR 422.2274(g)(2)(ii).
What is the TPMO disclaimer?
It is the standard statement a third-party marketing organization reads when it sells for more than one Medicare Advantage organization. It says how many organizations and products you represent in the caller's area and points them to Medicare.gov or 1-800-MEDICARE. The wording is set in 42 CFR 422.2267(e)(41) and must be spoken before any benefits are discussed.
Do I need to say the call is recorded?
Yes, say it at the start. Medicare marketing and sales calls must be recorded in full and kept for at least six years under 42 CFR 422.2274(g)(2)(ii): audio for the first three years, then audio or a complete and accurate transcript. The enrollment portion of a call is an enrollment record and is still kept for ten years. The caller should hear about recording up front. State laws on recording consent differ, so your counsel sets the exact wording for the states you call.
Can an AI agent use the same script?
Yes, with one addition. The AI says it is an automated AI assistant in its first sentence, before anything else, then gives the same recording notice and, where benefits may come up, the same TPMO disclaimer. Like a fronter, the AI never discusses plans, premiums or benefits. It screens the caller and warm-transfers them to a licensed agent.
Who approves the final script?
Your compliance team, and for Medicare usually the plan or FMO you contract with as well, since plans must oversee the TPMOs that sell for them. The scripts on this page are templates to start from. They are not legal advice, and they are not approved by CMS or any carrier.
How do I check agents follow the script?
Score recorded calls against a written checklist built from the script: notice given, disclaimer before benefits, no quotes from the fronter, clean transfer. Our free 10-call pilot does exactly that on ten of your recorded calls, with the line from each call behind every mark, so you see where the script slips.
Sources
Checked October 14, 2026.
- 42 CFR 422.2267(e)(41), TPMO disclaimer wording and timing
- 42 CFR 422.2274(g)(2)(ii), recording of marketing and sales calls, 6 year retention, audio for the first 3 years
- 42 CFR 422.2274(g)(3), TPMO lead generation disclosures, including transfer to a licensed agent who can enroll the caller in a new plan
- 42 CFR 422.2262(a)(1)(ix) and (xvii), no claimed CMS endorsement, no misleading use of the Medicare name
- CMS final rule CMS-4208-F3 / CMS-4212-F, 91 FR 17384, April 6, 2026 (disclaimer before benefits; enrollment records still kept 10 years; CY2027 marketing from October 1, 2026)
- 45 CFR 155.220(d), (j)(2)(i) and (j)(2)(iii), Exchange agreement, no misleading conduct, consumer consent
- 47 CFR 64.1200(b)(1) and (d)(4), caller identification on artificial voice and telemarketing calls
- FCC Declaratory Ruling FCC 24-17, February 8, 2024, AI-generated voices are "artificial" under the TCPA
Run Medicare, ACA or final expense lines?
Offer your clients AI voice agents and call quality monitoring, with live agents through our partner call center, or see how ten of your own recorded calls score against the script.