10.1 The Pre-Enrollment Checklist (PEC)
Key Takeaways
- The PECL requires agents to cover 8 specific topics with every MA/Part D beneficiary before an enrollment is completed: eligibility, providers, drug costs, health needs/costs, premiums, plan benefits, effect of coverage change, and administrative items.
- For telephonic enrollments, the PECL must be reviewed with the beneficiary before the enrollment is submitted — never mailed afterward as a courtesy.
- PECL is distinct from the Scope of Appointment: SOA authorizes what products can be discussed; PECL confirms the beneficiary understood the plan they are enrolling in.
- A beneficiary verbally waiving the PECL does not excuse the agent from completing it — CMS treats it as a required step, not an optional courtesy.
- CMS's CY 2026 MA and Part D Enrollment and Disenrollment Guidance (effective January 1, 2026) preserves the same 8-topic PECL structure used since September 2023.
Why the Pre-Enrollment Checklist Matters
Module 4 (Marketing & Sales Compliance) is the single heaviest-weighted module on the AHIP final at 25%, and the Pre-Enrollment Checklist (commonly abbreviated PECL or PEC) is one of its most frequently tested items because it is concrete, procedural, and easy to write a scenario question about. CMS built the PECL to close a specific gap: agents were enrolling beneficiaries who did not actually understand what they were signing up for — the wrong network, an unaffordable drug tier, or a plan that dropped their long-time cardiologist. The PECL forces a documented conversation about exactly those risks before the enrollment is finalized, not after.
Since a Centers for Medicare & Medicaid Services (CMS) requirement first effective September 2023 and folded into the annual Medicare Communications and Marketing Guidelines (MCMG) every year since, every agent who takes a Medicare Advantage (MA) or Part D enrollment must walk the beneficiary through eight specific topics. CMS's CY 2026 Medicare Advantage and Part D Enrollment and Disenrollment Guidance (released August 1, 2025, governing enrollment requests received on or after January 1, 2026) reaffirms the same eight-topic structure for the current plan year.
What the PECL Requires
The PECL is a standardized CMS-developed document that must be reviewed with a prospective enrollee before the enrollment is completed — for a telephonic enrollment, that means walking through it live on the call, before you submit the application, not mailing it afterward as a formality. For paper or online enrollment, the PECL content must accompany the enrollment form so the beneficiary can review it before signing.
| # | Required PECL Topic | What the Agent Must Confirm |
|---|---|---|
| 1 | Medicare eligibility | Beneficiary understands enrollment periods and when they can enroll in, disenroll from, or switch plans |
| 2 | Primary care providers & specialists | Preferred doctors and hospitals are in-network; beneficiary understands in-network vs. out-of-network cost differences |
| 3 | Prescription drug costs & coverage | Formulary tier placement and drug-cost comparison across the plans being considered |
| 4 | Specific health care needs & costs | Regular and anticipated medical services are affordable and covered under the plan |
| 5 | Premiums & cost-sharing | All out-of-pocket costs are disclosed — the beneficiary should never be surprised by a premium or copay |
| 6 | Plan benefits | Supplemental benefits and coverage limitations are plan-specific, not identical to a neighbor's or relative's plan |
| 7 | Effect of a Medicare coverage change | When existing coverage (e.g., a current MA plan, employer plan, or Medigap policy) will end once the new enrollment takes effect |
| 8 | Administrative items | Call-recording disclosure, Scope of Appointment (SOA) documentation, and how to file a complaint |
Notice that item 8 folds in two topics you already know from earlier chapters — SOA and call recording — which is exactly how AHIP likes to test the PECL: as the "wrapper" that confirms every other compliance step actually happened.
PECL vs. Scope of Appointment: The Trap
The most common exam trap is confusing the PECL with the Scope of Appointment (SOA) form, because both are mandatory pre-enrollment documents tied to timing rules.
| Scope of Appointment (SOA) | Pre-Enrollment Checklist (PECL) | |
|---|---|---|
| Purpose | Authorizes which products may be discussed at an appointment | Confirms the beneficiary understood the plan before enrolling |
| Timing | Generally documented 48 hours before the appointment (with narrow exceptions) | Reviewed before the enrollment is completed, during or right before the final application |
| Covers | Product types (MA, PDP, etc.) the agent is permitted to discuss | Eight specific content topics (eligibility, providers, drugs, costs, benefits, coverage change, admin) |
| Failure mode | Agent discusses an unauthorized product | Agent enrolls someone who never understood premiums, network, or drug costs |
Exam Scenario
Mr. Alvarez calls an agent's office after seeing a TV ad and says, "Just sign me up for the plan you advertised — I don't need to hear all the details." The agent has already obtained a valid SOA covering MA plans. Can the agent skip the PECL because the beneficiary said he doesn't want to hear it?
No. The PECL is a CMS-required step for completing the enrollment, not an optional courtesy the beneficiary can waive verbally. The agent must still cover all eight topics (briefly, if the beneficiary is impatient, but substantively) before submitting the application. Skipping it because the beneficiary "doesn't want to hear it" is a marketing violation that can result in the enrollment being flagged, a Complaint Tracking Module (CTM) case, or corrective action against the agent — even though the underlying enrollment might otherwise be legitimate.
Takeaways
- The PECL has eight required topics: eligibility, providers, drug costs, health needs/costs, premiums/cost-sharing, plan benefits, effect of coverage change, and administrative items.
- For telephonic enrollments, the PECL must be reviewed before the enrollment is completed — it cannot be sent afterward as a formality.
- The PECL is separate from, and does not replace, the Scope of Appointment — SOA authorizes the topics of discussion; PECL confirms the beneficiary understood what they enrolled in.
- A beneficiary asking to skip the PECL does not relieve the agent of the requirement to cover it.
- The CY 2026 CMS Enrollment and Disenrollment Guidance (effective January 1, 2026) keeps the same eight-topic PECL structure agents have used since 2023.
Under CMS rules, when must the Pre-Enrollment Checklist (PECL) be reviewed for a telephonic enrollment?
Which of the following is NOT one of the eight required PECL discussion topics?
A beneficiary tells an agent, 'Just enroll me, I don't need to hear the details.' What must the agent do?