CMS Final Rule for MA/part D overrides

Towards the bottom (of the long version), there is a bit of discussion about how they reviewed comments from outside parties... aka agents and uplines...

"Our finalized provisions simultaneously eliminate administrative payments but provide for higher compensation per enrollee. The increased compensation above the base line

compensation rate is $100 for each new MA or PDP enrollee. As discussed in section X.X of the preamble and section X.C.10 of the collection of information section, our goals were to: (1) provide sufficient funding which would compensate agents, brokers, and related entities for their work; (2) not to give excesses; and (3) to select increases consistent with current payments (that is not exceeding current administrative payments). In other words, the finalized provision transfers funds currently being allocated to administrative to compensation in a transparent and uniform manner. We have consequently scored this impact as having no cost, and therefore do not believe this will have an adverse effect, either on TMPOs, FMOs, or independent brokers."

I read this as they are not cutting their costs for commissions on the plan, but rather restructuring who gets what.

New to MA sale will pay the enrolling agent $711 and renew at $306.

New to PDP sale will pay the enrolling agent $200 and renew at $50.

Renewals will continue to be adjusted annually.

They dont explicitly say FMO will go away. But, it "eliminates administrative payments" which I was up until now interpreting to mean "overrides"

Sounds like there is still a bit of grey area in the final ruling. So I imagine the lawyers will figure that out.

All that being said, I think the T65 market will be even more competitive than before, for marketing.

There is clear language that TMPO organizations cannot share the beneficiary info without their prior written consent. It appears that TPMO is meaning lead generation and collection. Looks like TPMO argued in the past that when a person filled out their info, clicked a link, or whatever other way they engaged, there was an agreement from the beneficiary to have their information sold and shared... and now they are nixing that.

I would imagine this is how "do not call" lists were circumvented, outside of blatantly breaking the law.

If CMS wants to really kill the call centers, with this new language, they'd probably just have to amend it, with an addition to prevent an LOA business model with MA sales. Otherwise, I dont see any real changes.

Am I missing something?

(I edited some typos, and typo figures)
 
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whats medicare center?
It is an enrollment software platform generically called Sunfire, but different names depending who your FMO upline. My upline refers to it as “Simply Enroll”, but it is still Sunfire. If HealthSherpa is free to ACA enrollment, I’m not sure why Sunfire couldn’t also be free for MA enrollments?
 
The way I’m reading it the FMO’s still keep theirs but they can’t share it with agents. And the agents get $100 increase.

Is that right?
 
The way I’m reading it the FMO’s still keep theirs but they can’t share it with agents. And the agents get $100 increase.

Is that right?
Totally incorrect. There’s no adminstrative payments above the $711 to the agent . No marketing money either . The ruling clearly states they raised the commission $100 “ for the agents increased costs such as paying for enrollment software “ In so many words cms wants fmo’s and anyone that used to override out of the mapd business . They view them as having the incentive of money as a way they “steer” clients to specific plans . As i always said . The total override on mapd is 80% which is insanity .
 
It is an enrollment software platform generically called Sunfire, but different names depending who your FMO upline. My upline refers to it as “Simply Enroll”, but it is still Sunfire. If HealthSherpa is free to ACA enrollment, I’m not sure why Sunfire couldn’t also be free for MA enrollments?
 
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