Face to Face Required? You Be the Judge.

[plannerman]

Straight from AHIP today:


One of your colleagues argues that face-to-face meetings with potential enrollees should be required because they cannot make an appropriate decision with the minimal information that can be provided over the phone or in small brochures. How should you respond to this argument?


Choose one answer.

a. This is correct. In fact the Medicare Agency requires potential enrollees to meet face to face with an agent, plan representative, or State health Insurance Assistance Program representative before permitting a beneficiary to enroll in a MA or Part D plan Incorrect
b. This is a reasonable argument, but requiring face to face meetings in order to answer questions or complete an enrollment application is not permitted unless an agent first communicates with the beneficiary via phone, email, or reply card. Incorrect
c. This is incorrect. Brokers and agents cannot require face to face meetings in order to answer questions or enroll a Medicare beneficiary. Correct
d. Some states have agreed with your colleague and whether such a policy is required is based on state law. You should consult with your state insurance department to see what they say. Incorrect
.

Source: Prohibited Practices: Marketing Activities

The right answer is C, according to AHIP. So if any of the companies say any different at least we have it posted right here. Like they care

 

[sman]

Nothing new to those who are experienced. That doesn't stop one carrier from requiring F2F if you want to get paid. Hopefully that changes since they are being bought by another carrier who doesn't require it.

 

[sshafran]

Nothing new to those who are experienced. That doesn't stop one carrier from requiring F2F if you want to get paid. Hopefully that changes since they are being bought by another carrier who doesn't require it.

Yup. From said debil carrier, "WE don't ask you to require your prospect to meet you F2F. But if the prospect won't meet, since the prospect can call in to us directly, it just works (and saves us from paying you)."

That's an almost verbatim quote....

At least they allow AOR change with pay the following year. So... So very kind of them.

 

[GreenSky]

And here's what Humana sent me:

**Chapter 3 of the CMS Medicare Marketing Guidelines have specific provisions related to telephonic presentation and enrollment that indicate they must be done in a call center environment. The calls must be recorded and the scripts approved by CMS. There are not any exceptions in the guidelines for field agents (not acting as call centers) to present and enroll over the telephone in the absence of these protections. Therefore, if an agent is NOT contracted & certified as a TELESALES agent, he/she should NOT enroll clients over the phone.***

Humana does not currently support FIELD AGENTS making telephonic sales presentations. Since this is an unapproved process, agents who complete telephonic presentations run the risk of a Section A violation. Per CMS guidance, if the agent is a field agent, a telephonic enrollment cannot be done. It is NEVER acceptable for an agent to simply mail a paper application without an SOA and the presentation being completed.

When I asked them for a copy of the CMS guideline they told me "Please contact CMS regarding their guidelines on face to face sales presentations." Naturally I thanked them for their continued support.

The bottom line is the guidelines precluding F2F are for call centers who tend to employ non-licensed people, not those of us who are licensed and actually understand that Humana's position is pure bullsheit.

Maybe things will change when the company that backed Obamacrap to the point that their former CEO quit and got hired in the Obummer administration as his reward completes their purchase of the debil.

Rick

 

[MedicareAgent]

I did many online enrollments and never met the consumer. I emailed the packet and if they want it, i online enrolled them. Never did a "presentation". Some rules are just stupid and I answer to cms first.

 

[GreenSky]

I did many online enrollments and never met the consumer. I emailed the packet and if they want it, i online enrolled them. Never did a "presentation". Some rules are just stupid and I answer to cms first.

And if Humana pulls your contract how much help would you get from CMS?

BTW, I'm not saying I disagree with you but do you think your "CMS defense" will keep them from taking action?

Rick

 

[MedicareAgent]

No no no of course cms won't stand behind me, no one ever stands behind the agent. I'm just saying this is how I do it.
I cannot be in my office and doing in home appts at the same time and instead of them going to someone else and being lied to, I take my chances so I know the customer got exactly what they requested.

 

[sshafran]

It is NEVER acceptable for an agent to simply mail a paper application without an SOA and the presentation being completed.

And therin lies the rub.

I'd argue with the debil that mailing a prospect a complete package, and them mailing / faxing back a completed app, is NOT a telephonic enrollment.

A *telephonic* enrollment would utilize the e-app and would likely not mail a full packet pre-enrollment.

But they don't listen / care.

 

[WCMason]

I've heard about their F2F requirement only on this forum. I've always wondered about a couple of things:

1) Why does their annual certification, which is where they set out their rules for agents regarding their products, mention nothing about F2F being required? They accept AHIP as part of their own annual certification and AHIP specifically addresses the issue in the material and in an exam question. If their company policy differs, this would be the place to make that clear. 2) If they require F2F why do they have an online enrollment application on the agent portal that sends an email to the applicant to sign electronically? This seems designed specifically for agent-assisted, non-F2F situations. In a F2F situation it seems much easier to complete a paper application than deal with a two-step online process.

It seems there is some lack of clarity about two different things: 1) giving plan-specific information when requested over the phone and then sending enrollment information to complete on their own and submit electronically or by mailing back a paper application, and 2) taking an enrollment over the phone that the agent completes on the call. The latter is clearly not allowed by CMS or carriers. The former seems clearly allowed by CMS so long as the initial contact was compliant (for example, not a cold call). In fact, it appears that an agent who refuses to provide specific plan information when requested on the phone and instead requires a F2F meeting is in violation.

Humana's language in the quotes in previous posts connects "sales presentation and enrollment." But when those two are not connected, as in a non-F2F sales presentation where enrollment occurs later by the beneficiary doesn't seem to be addressed by them in anything I've seen. I do all of my appointments F2F except for a rare spouse of an existing client situation, and write 90% med supp, so fortunately this isn't a problem i have to contend with.

 

[GreenSky]

2) If they require F2F why do they have an online enrollment application on the agent portal that sends an email to the applicant to sign electronically? This seems designed specifically for agent-assisted, non-F2F situations. In a F2F situation it seems much easier to complete a paper application than deal with a two-step online process.

I asked exactly the same question. What I was told in a phone call was that it's there in case you don't have the application.

Since the application is included in the enrollment kit that would mean you also do not have a summary of benefits. So the presentation would definitely be non-compliant.

I didn't bother pointing that out because by that time I had gone back and forth with a bunch of emails and phone calls about them stealing my client who was too stupid to figure out how to sign the e-app, called into Humana per their instructions and an inside sales rep simply stole my client. (That's when they told me about the F2F requirement).

Just another reason they are "affectionately" known as the debil.

Rick