Offering Gifts for Sign-ups and Referrals?

slyrock1

Expert
35
Anyone know if we're allowed to offer an up to $15 gift card or something similar in retail value, for referrals and new signees?

And would we be allowed to convey this in a facebook message?
 
Don't know if you can, but why would you want to? Depending on your area or office location I would not see any need to offer incentives. Put a sign out "Open Enrollment Health Insurance Exchanges Oct 1" or something to that effect.

Besides, forget to offer just one prospect a card or whatever and you're in deep crap, REBATE ring a bell?
 
The insurance rebating laws are a slippery slope.

http://hnas.com/LinkClick.aspx?fileticket=UWZdtOBp_uw= (Doesn't address the $ amount exemptions in some states. I believe you may spend up to $15 in NY before it's an issue, i.e. I can pay for a slice of pizza for a client, but can't buy them a steak. A discount applied to premium is ALWAYS rebating as far as I know, and giving a gift card to a client who just signed up and has to pay premium is really close to doing just that.)

Moral of the story, it's probably considered rebating and you'll probably get in trouble. New signees: definitely in trouble. Rewarding a referral from a non-client is probably fine, but rewarding a client will get you in trouble.

NAHU has been working in NY to allow "consultative services" that a licensed professional would usually charge for, but is provided to clients at no charge, to be excluded. I was actually in Albany this past April lobbying with them, and this was a big point on our agenda. That's how tight the laws are, you can't even advise existing clients if you charge non-clients a fee...
 
Anyone know if we're allowed to offer an up to $15 gift card or something similar in retail value, for referrals and new signees?

And would we be allowed to convey this in a facebook message?

Before implementing any marketing strategy, contact your department of insurance with a detailed proposal that you are working on. Every state can be a bit different. I know in Iowa, rebating is not a gray area and one that the commissioner will make you an example on. I don't know the rule inside and out, but I know I will never end up in a hearing because I don't even think about getting involved in giving anything to anyone except my business card. I haven't felt the need for it either. If you give them great customer service, you won't need any other incentive.
 
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