Sales Oversight — Essential Guidelines

All agents are expected to comply with the Centers for Medicare & Medicaid Services (CMS) regulations and guidelines, federal and state laws, and health plan rules, policies, and procedures.  But what does that mean, and how can health plans enable their employed sales staff and contracted agents to stay compliant while achieving target goals and growth?

Some organizations may have sales management monitoring tools and processes to review the agent’s compliance, quality, and performance thresholds. In most cases, sales management personnel are required to provide ongoing monitoring of agent sales activities and performance.

Below are a few key components to Medicare sales force and distribution channel management:

  • Ensure all agents selling Medicare products complete and pass all required training
  • Communicate all product and regulatory information
  • Ensure agents participate in any required remedial training
  • Communicate the results of all ride-along evaluations
  • Document any complaints or corrective action plans in the agent’s file, which should be held for a minimum of two years
  • Ensure any corrective action plan is completed and reported back to the health plan
  • Report terminations of any agents/brokers to the state and the reason(s) for the termination

Gorman Health Group (GHG) suggests implementing a variety of compliance monitoring programs to ensure all agents are conducting sales, marketing, and enrollment activities in accordance with federal, state, and health plan regulations, rules, and guidelines. With the Annual Election Period (AEP) just several weeks away, health plans should be finalizing their sales oversight and agent performance standards. Regan Pennypacker, GHG’s Senior Vice President of Compliance Solutions, says: “We know it’s not easy. These activities take a village. A solid partnership between the creative minds in Sales and the rules-minded Compliance staff is critical to success. A sponsor with a well-planned roadmap for AEP will be one step ahead of competitors that have not executed as well.”

To promote compliant behavior, health plans, sales management, agency owners, and agents should take an active approach to compliant behavior — attend additional training, understand and follow the rules and regulations outlined in the Medicare Marketing Guidelines, and always lead by example.

For more information, please contact Carrie Barker-Settles at



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