What constitutes a sales call?
Any call that is related to what CMS calls the “chain of enrollment,” which has been defined as the events from a beneficiary becoming aware of an MA/PDP plan to the end of the enrollment process. This means that calling leads, scheduling appointments, collecting scopes of appointment (telephonically), presenting plans, collecting drug and doctor lists, and phone enrollments would all fall under this guidance. This list is not exhaustive, and other calls that contain marketing content will also need to be recorded and retained.
How can I record and store calls?
We recommend reaching out to your current phone provider to see if they offer call recording. If they do not, or it seems cost prohibitive, consider a VOIP phone system that can be used in the office or the field. Some common options are Ring Central, 8×8, and Vonage. For storage, you will need to develop a process for sorting and storing the calls either on a local drive or cloud-based storage. Since these calls contain sensitive data, most free storage accounts will not be HIPAA compliant. We are currently researching the best options for agents to compliantly store this data.