Cross Selling on MA Appt

[Tom Highway]

The MIPPA rules say that an agent CANNOT cross sell another insurance product on an appointment for medicare advantage, and canot market other insurance products on a MA appt.

If you are an agent who sells these other products, like FE, LTCi, etc, what exactly CAN you do? What would be appropriate to do or say that does not cross the line?

At the end of the appt, could you say "I know you may have other insurance needs, like long term care or final expense, and I would be happy to review this and give you a quote, but medicare rules say that I cannot discuss this with you today. I will not go around medicare's rules, so if you'd like to know about these things, please call me. OK?"

Is doing this against the rules - would this fall under the "marketing" umbrella, and therefore not be allowed?

Is there any way way that you can segue into other products at all while staying within the legal guidelines - if so, how?

 

[jdeasy]

The MIPPA rules say that an agent CANNOT cross sell another insurance product on an appointment for medicare advantage, and canot market other insurance products on a MA appt.

If you are an agent who sells these other products, like FE, LTCi, etc, what exactly CAN you do? What would be appropriate to do or say that does not cross the line?

At the end of the appt, could you say "I know you may have other insurance needs, like long term care or final expense, and I would be happy to review this and give you a quote, but medicare rules say that I cannot discuss this with you today. I will not go around medicare's rules, so if you'd like to know about these things, please call me. OK?"

Is doing this against the rules - would this fall under the "marketing" umbrella, and therefore not be allowed?

Is there any way way that you can segue into other products at all while staying within the legal guidelines - if so, how?

If you are there for MA and or PDP, you cannot bring up anything else. The client has to initiate the conversation. Sure, there are ways to get that done without being a direct violation, but, if there is a problem later, you will be ratted out.

If you are there for FE, LTC, etc. You cannot bring up MA and or PDP. The client has to initiate that conversation. If they do, you can pull out the SOA and have it signed and then discuss part C and or D. The 48 rule went by the wayside. However, some companies still have more restrictive rules than CMS. For example, when Wellcare was still doing business, they had a 2 hour rule still in effect for these situations.

The key is still that the client has to initiate interest. If they do and you can document it, you are OK. I had it happen yesterday. I was there for FE, the guy noticed on my business card that I do med sups and asked about it. Since he was under age 65, the med sup was just too pricey for him, {$300 mo.}. He asked if there was any other option. I told him about MA plans, but, since I don't write them anymore I gave him the number of a guy to call that would come and meet with him. If I were still doing MA, it would have been fine for me to have had him sign the SOA and proceed. I would have written on the SOA that he inititiated the discussion and I would have made sure he knew that was written on there.

 

[stormtracker]

In years past, "cross selling" an MA prospect meant stepping across the threshold of the door, turning around and stepping back in. Me thinks CMS got wise to this.

 

[JustinUpright]

Would it not be better to just collect their information and put them in as your customer and maybe call them see how they are doing and then offer any other product you can help with. Just an option.

Once they ask you to come and show them MA or sups then they are technically your client. Sell or no sell I would but them in my database till they tell me to stop calling or emailing them.

 

[Tom Highway]

Would it not be better to just collect their information and put them in as your customer and maybe call them see how they are doing and then offer any other product you can help with. Just an option.

Once they ask you to come and show them MA or sups then they are technically your client. Sell or no sell I would but them in my database till they tell me to stop calling or emailing them.

Not so much, because the permission to call and scope of appointment is a limited, one-time event. Once you contact the person once for MA, if they don't buy, you have to have a permission to call to contact them again, and it has to be specific for MA.

The big way around this is to sell supplements, because you can cold call or do whatever you want (within reason), but once somebody has a scope for a MA appt, it's like a vice is clamped down on your cojones.

I wonder why CMS is leaving supplements alone for the time being.......

 

[Lee Sanford]

I wonder why CMS is leaving supplements alone for the time being.......[/quote]


MIPAA said CMS had to do something about MA and PDP regarding commissions and marketing, which they did (or are still in the process of doing???). It also said that they had to address Med Supp. In April, they did that by adopting the 2007 NAIC recommendations. Those recommendations include mandating a '2X first year/X years 2-6' formula. Here's the quote:


A. An issuer or other entity may provide commission or other compensation to an agent or other representative for the sale of a Medicare supplement policy or certificate only if the first year commission or other first year compensation is no more than 200 percent of the commission or other compensation paid for selling or servicing the policy or certificate in the second year or period.
B. The commission or other compensation provided in subsequent (renewal) years must be the same as that provided in the second year or period and must be provided for no fewer than five (5) renewal years.

Sound familiar? This is also what the current MA and PDP comp structure is based on. So, in addition to the mandatory plan structure and regulating the comp, I'd look for Med Supp to be thrown into the hopper with MA and PDP regarding marketing compliance on June 1, 2010, as well.

Below is the link to the full posting of the new regulations in the Federal Register.

http://edocket.access.gpo.gov/2009/pdf/E9-9272.pdf

Lee

 

[jdeasy]

I wonder why CMS is leaving supplements alone for the time being.......

MIPAA said CMS had to do something about MA and PDP regarding commissions and marketing, which they did (or are still in the process of doing???). It also said that they had to address Med Supp. In April, they did that by adopting the 2007 NAIC recommendations. Those recommendations include mandating a '2X first year/X years 2-6' formula. Here's the quote:


A. An issuer or other entity may provide commission or other compensation to an agent or other representative for the sale of a Medicare supplement policy or certificate only if the first year commission or other first year compensation is no more than 200 percent of the commission or other compensation paid for selling or servicing the policy or certificate in the second year or period.
B. The commission or other compensation provided in subsequent (renewal) years must be the same as that provided in the second year or period and must be provided for no fewer than five (5) renewal years.

Sound familiar? This is also what the current MA and PDP comp structure is based on. So, in addition to the mandatory plan structure and regulating the comp, I'd look for Med Supp to be thrown into the hopper with MA and PDP regarding marketing compliance on June 1, 2010, as well.

Below is the link to the full posting of the new regulations in the Federal Register.

http://edocket.access.gpo.gov/2009/pdf/E9-9272.pdf

Lee[/quote]


MA plans and PDP are part of the Medicare system. Private companies are providing basic Medicare benefits plus anything else in the plan . That's why CMS has a say in how they are marketed to Medicare eligibles.

Medigap policies are not part of Medicare. They have standardized rules for Medigap, but, they are not part of the Medicare system, they are a "supplement". I can't see how CMS would have leg to stand on to try and implement marketing rules for a supplement.

Of course, if the companies get in bed with CMS like they did with MA anything is possible.

 

[JustinUpright]

My point is if they buy or don't buy MA they can be called anytime for FE or life insurance so if you have already spoke with them about MA it wouldn't be a cold call and it wouldn't be about MA so no regulation on that. Correct me if I am wrong just seems if I can contact them about any other insurance other than MA's by cold calling then if I contact them after a MA appointment on other products would be ok.

 

[wstcst1]

My point is if they buy or don't buy MA they can be called anytime for FE or life insurance so if you have already spoke with them about MA it wouldn't be a cold call and it wouldn't be about MA so no regulation on that. Correct me if I am wrong just seems if I can contact them about any other insurance other than MA's by cold calling then if I contact them after a MA appointment on other products would be ok.

I saw that no one answered this. Any experts know the answer to this?