CMS Oversite of Agent Websites

I've looked at a lot of "third party" websites and not once have I ever seen one that represented a Med supp policy as a Part C Medicare Advantage plan, used superlatives, or asked health questions.

On the other hand, BCBS of TN, when you go to their website for Part C quotes, go to "Choose a Plan," then "Shop and Enroll Now," and finally "Compare Plans," it not only asks you if your health is good or poor, but even your marital status. What's up with that?
 
There was a website called "www.medicaregov.us" that basically could've served as the poster child for the latest CMS memo. It only takes one bad apple to ruin the entire lot.
 
Would this include those affiliate websites that drive traffic to lead vendors? If so, I can definitely see that. Many of those who throw up those sites have no license or training. They just know black hat seo. Some are even outside of the US. Are agents who buy leads supposed to be responsible for 3rd party sites? Am I reading too much into this?? If so, how the heck is an agent supposed to know where those leads come from??
 
CMS's mission is to protect the public from unscrupulous agents.

Perhaps if there were no unscrupulous agents there might not be as many rules and regulations.

"The fault, dear Brutus, is not in our stars,
But in ourselves, that we are underlings."

Shakespeare, Julius Caesar (I, ii, 140-141)
 
Would this include those affiliate websites that drive traffic to lead vendors? If so, I can definitely see that. Many of those who throw up those sites have no license or training. They just know black hat seo. Some are even outside of the US. Are agents who buy leads supposed to be responsible for 3rd party sites? Am I reading too much into this?? If so, how the heck is an agent supposed to know where those leads come from??

I don't think you're reading into this too much at all. I'm surprised that so many internet sites can generate leads without giving any thought for being licensed, but it sounds like CMS is really going to crack down on it. How great would it be to pay for an internet lead only to find out it was a CMS secret shopper?
 
How about paying for a lead and being responsible for how it was generated and what website it came from... that's a big liability with internet leads. I don't buy them any more, but I know some people still do. Wonder how Bob Klee feels? Would he be able to pass the buck to you as the agent if the originating site was non-compliant??
 
Would this include those affiliate websites that drive traffic to lead vendors? If so, I can definitely see that. Many of those who throw up those sites have no license or training. They just know black hat seo. Some are even outside of the US. Are agents who buy leads supposed to be responsible for 3rd party sites? Am I reading too much into this?? If so, how the heck is an agent supposed to know where those leads come from??



I think CMS has always been clear on the fact that it is the agents responsibility to have compliant initial contact with the consumer. Being ignorant of the fact that a purchased lead was generated from a non compliant website is not a defense for violating CMS marketing rules.It is easy for agents to get away with using these type of leads because the only time they would get caught is when there is a consumer complaint .The first question the carriers ask on an STI is always " how did you make initial contact with beneficiary?" Going forward if the answer to this question is the initial contact was made from an OB call from an internet lead I suspect the carriers may scrutinize the lead source more than than they use too.
 
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