Medicare Advantage calling playbook for permissioned outreach blocks

Counsel review notice

This is a C fit and this playbook is an operating description, not a compliance program. 42 CFR 422.2264(a)(2)(iv) prohibits unsolicited telephone solicitation, cold calling, robocalls, text messages and voicemail messages by Medicare Advantage organizations and their agents and brokers. Everything below assumes outreach rests on documented beneficiary requests that your compliance owner reviewed, under CMS marketing guidance, carrier agreements and your counsel’s direction. Nothing here is legal or compliance advice.

The structure: three blocks, three scopes

The category does not have a prospecting block. It has permissioned workflows, and the discipline is keeping them separate.

Consultation request callbacks. The core block. The beneficiary asked for a consultation, the request language is on the row, and the call books the time with a licensed agent. Scope follows the request.

Reschedule block. The beneficiary asked to move an appointment. This is administrative, it references the existing appointment, and it books a new time without expanding anything.

Member service block. Existing members with a service question. Different category from marketing entirely, with its own path and its own documentation, and it does not belong in the same queue as consultation work.

List hygiene: the permission record is the list

Load records with the request language, the submission date, the source, the assigned licensed agent and the compliance review status. The permission basis is not metadata; it is the qualification. A record that cannot show its request does not dial, and a record whose permission is questioned routes to compliance, never to a judgment call on the floor.

Suppress aggressively and immediately. A stop request, a family member saying the beneficiary passed, a wrong number reported as such: each goes to permanent suppression the day it surfaces. Revocations under 47 CFR 64.1200(a)(10) must be honored within a reasonable time not to exceed ten business days; in this category, same-day is the only defensible speed.

Attempt policy

Permissioned beneficiaries answer, so the cadence is short.

• Attempt 1: same or next business day, within the beneficiary’s preferred window if the form captured one.
• Attempt 2: two days later, different hour.
• Then stop and route the record back to the compliance owner or the scheduling queue per your process.

There is no five-touch cadence in this category, because persistence reads as pressure to a beneficiary and pressure is what the rules exist to prevent. Calling hours stay inside 8 a.m. to 9 p.m. local time under 16 CFR 310.4(c) and 47 CFR 64.1200(c)(1), and quiet hours follow the beneficiary’s local time.

Dispositions a compliance owner can audit

• Consultation booked: day, time, attendees, confirmed scope.
• Scope of appointment documented: before any expanded topic was discussed.
• Requested materials sent: only what was asked about.
• Not eligible, follow up in the permitted window: with the date.
• Not interested: with the request withdrawn.
• Do not call permanently: any stop request.
• Route to compliance: any questioned permission basis.

Every disposition carries a date and a named owner. An audit that samples called rows against their source documents should never find a row whose permission basis cannot be produced.

Working three lines on a permissioned list

DialBreeze rings up to three numbers per operator and the operator takes the live answer, with a recorded voicemail dropping on the rest. Permissioned lists connect at high rates, so three lines is rarely necessary; one or two is the common configuration, and whether even that is permitted for a given campaign is a CMS and carrier question answered before deployment. Recording feeds the AI summary. Several states require all parties to consent to recording, including Washington under RCW 9.73.030 and California under Penal Code 632, and a beneficiary conversation is exactly where those statutes matter. DialBreeze applies your internal lists, quiet hours and attempt caps; it does not decide whether a beneficiary may be contacted.

Where the AI summaries go

The summary helps the licensed agent prepare: the request as restated, the confirmed scope, the plan question, the caregiver on the appointment, the booked time. It is not a compliance record, does not prove consent, and does not substitute for the documentation CMS guidance and your carrier require. Verify plan names and benefit details against the recording before the consultation, and route the record to the compliance owner for the required documentation after it. Where protected health information is involved, the HIPAA business associate framework at 45 CFR 164.504(e)(1) governs how your tooling contracts are structured, not just your carrier’s.

KPI targets as ranges

Reference points measured in DialBreeze production use (last 90 days to 2026-09-26, three-line sessions, one operator per session): median of about 85 dials per active calling hour, about 600 dials per operator day, and a 17.8 percent person-connect rate. Aggregate measured values, not a promise, and permissioned beneficiary lists will not look like that profile.

For a permissioned desk:

• Consults booked per operator-week: track it weekly and set the target from your own first two weeks of data.; count it on healthy request volume.
• Connect rate on fresh requests: track it weekly and set the target from your own first two weeks of data. , because the beneficiary asked for the call.
• Show rate: track it weekly and set the target from your own first two weeks of data.; the lever is caregiver invited and a confirmation call.
• Scope documented before discussion: track it weekly and set the target from your own first two weeks of data. 100 percent, which is a floor, not a range.
• Records routed to compliance: every questioned one, within the day.

Compliance, disclosure and the parts that belong to counsel

The CMS layer governs everything: 42 CFR 422.2264 on beneficiary contact and unsolicited outreach, 42 CFR 422.2274 on agent, broker and third-party marketing organization conduct and compensation, and the CMS marketing guidance that operationalizes both. The calling layer applies on top: hours, revocations, recording consent and the National Do Not Call Registry where applicable. Your compliance owner approves the list, the scripts and the dispositions before the block runs, and reviews them after. This playbook is an operating guide, not legal advice, and the counsel review is not optional in this category.