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I say F*CK CMS!!! I'm an Independent Insurance Agent and I can do WTF I want.Within OLA - if the door knock got you in - then the PTC / SOA is best worked 48 hours later for a CMS regulated Part C or Part D..
CMS changed it up some - but, with the Big 3, we do it like above so there is absolutely no compliance issues.
Others may feel free to do it however they wish.