TPMO (third-party marketing organization): what it means in pay per call

TPMO (third-party marketing organization): CMS's term for organizations and individuals, including lead generators and call centers, that sell or market Medicare Advantage or Part D plans for compensation.

How it works in pay per call

TPMOs must give a standardized disclaimer on calls with beneficiaries (42 CFR 422.2267(e)(41)) and follow CMS rules on call recording and marketing. CMS's CY2027 rule (published April 6, 2026) changed the disclaimer's timing and content for marketing starting October 1, 2026.

The CY2025 rule requires prior express written consent, given one TPMO at a time, before a TPMO shares a beneficiary's personal data with another TPMO. A federal court left that requirement in place in 2025.

Example

Example: a lead-gen company running Medicare ads and transferring calls to a plan's agents is a TPMO. It must give the CMS disclaimer on the call and follow CMS's recording and consent rules.