DOI Investigation

[sshafran]

What confuses me is what do you put down as the initial method of contact on the SOA form.

Humana gives an option to checkmark: Agent Contact. I think that would raise a red flag because there's no way on the Humana SOA form to explain that this was a FE presentation that led to a MA conversation.

UHC's form gives you a little room but not much. Not sure what to write in there.

My (recently former) upline has been very vague about this, which leads me to believe their probably not 100% compliant in this area.

Especially when they door knock for med supp but over 75% of their book is MA.

Use a generic soa...

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What confuses me is what do you put down as the initial method of contact on the SOA form.

Humana gives an option to checkmark: Agent Contact. I think that would raise a red flag because there's no way on the Humana SOA form to explain that this was a FE presentation that led to a MA conversation.

UHC's form gives you a little room but not much. Not sure what to write in there.

My (recently former) upline has been very vague about this, which leads me to believe their probably not 100% compliant in this area.

Especially when they door knock for med supp but over 75% of their book is MA.

If you have to write something... final expense appointment, asked about health ins, new appt scheduled...

 

[John Galt]

So anyone who sells MA is a CMS buttboy?

No not everyone, if you are in the southeast you are excluded lol, you know we don't roll that way. It's not an insult, just an opinion and you know I absolutely have no idea what I'm talking about lol

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What confuses me is what do you put down as the initial method of contact on the SOA form.

Humana gives an option to checkmark: Agent Contact. I think that would raise a red flag because there's no way on the Humana SOA form to explain that this was a FE presentation that led to a MA conversation.

UHC's form gives you a little room but not much. Not sure what to write in there.

My (recently former) upline has been very vague about this, which leads me to believe their probably not 100% compliant in this area.

Especially when they door knock for med supp but over 75% of their book is MA.

See, exactly the kind of crap I'm talking about. By the way I don't mind driving out of my area to sell FE or medsup, it's a non issue so leaving the ma on the table for others doesn't bother me as my local area has high ma penetration, I'd rather sell medsupps.

 

[yogooglethis]

Use a generic soa...

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If you have to write something... final expense appointment, asked about health ins, new appt scheduled...

Initial contact method on SOA would still have to be noted as an OB call if that's how how you first made contact with FE prospect .If a significant part of your income is from MA enrollments and all or a majority of your MA sales are generated from using FE appointments as a pivot to MA then you would have the same issue that the OP here may have .If you read the the MA Marketing rules chapter 3 you will see that CMS strictly prohibits bait and switch strategies to generate MA leads.Not that an FE agent can't come across MA prospects compliantly in the course of selling FE but its all in the intent. If you make an MA sale by initiating discussion about their health insurance that is no different in CMS eyes then approaching a senior in the grocery store and starting a conversation about their medicare insurance.

Will you caught if you do it occasionally ? - probably not. But if you consistently rely on these type of methods to get your MA sales and you ever get a complaint about anything the client might be upset about concerning the plan the first of the 25 questions they always ask is: How did you meet this person? In their investigation the compliance dept. of carrier will ask their member who was the one who brought discussion about health ins. at your FE appointment. If compliance dept. is suspicious of your initial contact methods they can contact other people you enrolled to look for a pattern. To keep out of trouble with compliance dept. I assume that every enrollment I do will file a complaint and that I will pass the smell test with no problem every time because it's possible that just one complaint can put an MA agent out of business

 

[John Galt]

Initial contact method on SOA would still have to be noted as an OB call if that's how how you first made contact with FE prospect .If a significant part of your income is from MA enrollments and all or a majority of your MA sales are generated from using FE appointments as a pivot to MA then you would have the same issue that the OP here may have .If you read the the MA Marketing rules chapter 3 you will see that CMS strictly prohibits bait and switch strategies to generate MA leads.Not that an FE agent can't come across MA prospects compliantly in the course of selling FE but its all in the intent. If you make an MA sale by initiating discussion about their health insurance that is no different in CMS eyes then approaching a senior in the grocery store and starting a conversation about their medicare insurance.

Will you caught if you do it occasionally ? - probably not. But if you consistently rely on these type of methods to get your MA sales and you ever get a complaint about anything the client might be upset about concerning the plan the first of the 25 questions they always ask is: How did you meet this person? In their investigation the compliance dept. of carrier will ask their member who was the one who brought discussion about health ins. at your FE appointment. If compliance dept. is suspicious of your initial contact methods they can contact other people you enrolled to look for a pattern. To keep out of trouble with compliance dept. I assume that every enrollment I do will file a complaint and that I will pass the smell test with no problem every time because it's possible that just one complaint can put an MA agent out of business

I love how you MA guys keep making the case for me to NOT sell this crap. Thanks again, really. You have saved me much time and energy.

 

[sshafran]

Initial contact method on SOA would still have to be noted as an OB call if that's how how you first made contact with FE prospect .If a significant part of your income is from MA enrollments and all or a majority of your MA sales are generated from using FE appointments as a pivot to MA then you would have the same issue that the OP here may have .If you read the the MA Marketing rules chapter 3 you will see that CMS strictly prohibits bait and switch strategies to generate MA leads.Not that an FE agent can't come across MA prospects compliantly in the course of selling FE but its all in the intent. If you make an MA sale by initiating discussion about their health insurance that is no different in CMS eyes then approaching a senior in the grocery store and starting a conversation about their medicare insurance. Will you caught if you do it occasionally ? - probably not. But if you consistently rely on these type of methods to get your MA sales and you ever get a complaint about anything the client might be upset about concerning the plan the first of the 25 questions they always ask is: How did you meet this person? In their investigation the compliance dept. of carrier will ask their member who was the one who brought discussion about health ins. at your FE appointment. If compliance dept. is suspicious of your initial contact methods they can contact other people you enrolled to look for a pattern. To keep out of trouble with compliance dept. I assume that every enrollment I do will file a complaint and that I will pass the smell test with no problem every time because it's possible that just one complaint can put an MA agent out of business

I see what you are saying and I appreciate the caution. Here's how I see it:

...it wouldn't be outbound call. It would be FE direct mail. It's not bait and switch to meet with someone for life insurance, take care of that, and cross-sell the fact that you also help people with their health insurance. You have no clue what they have (with FE - lots of Medicaid).

If "intent" is to use an FE mailer to sell MA, then you are correct. But that's a pretty dumb marketing plan, in my opinion. My intent is to get the FE sale...then the health insurance sale, regardless of whether it is ma or med supp.

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[yorkriver1]

RE: calling in an attorney. Any reason for not reporting Medicare sales allegations to E&O carrier? Several posts have mentioned a lawyer, without mentioning E&O. I get that we may not want to increase premium costs, lose coverage, etc. It also can pay for defense costs if they mount up. There also may be a requirement of the E&O carrier to report an incident that could turn into a claim asap when situation is known, in the event that things really go south.
Since my E&O has a similar deductible to some health plans these days, it's certainly not 1st dollar coverage, it may cost less for a lawyer than the deductible, but maybe not.
I'd rather not involve E&O if a situation arises, but it seems like something to consider carefully.

 

[scagnt83]

RE: calling in an attorney. Any reason for not reporting Medicare sales allegations to E&O carrier? Several posts have mentioned a lawyer, without mentioning E&O. I get that we may not want to increase premium costs, lose coverage, etc. It also can pay for defense costs if they mount up. There also may be a requirement of the E&O carrier to report an incident that could turn into a claim asap when situation is known, in the event that things really go south.
Since my E&O has a similar deductible to some health plans these days, it's certainly not 1st dollar coverage, it may cost less for a lawyer than the deductible, but maybe not.
I'd rather not involve E&O if a situation arises, but it seems like something to consider carefully.

Re-read the thread. We already covered the issue of E&O in this situation. Specifically on pages 6 7 & 8.

 

[gordon112]

So anyone who sells MA is a CMS buttboy?

The ACA health agent of the exchange would be a true buttboy of the current government.

 

[sman]

I love how you MA guys keep making the case for me to NOT sell this crap. Thanks again, really. You have saved me much time and energy.

No need to fool with it. Just send them my way.

 

[sshafran]

No need to fool with it. Just send them my way.

What...You don't have enough $213/yr lifetime renewals?

Makes the FE renewal laughable... (Of course...we don't get $600+ 1st year)...

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