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I sent this to Humana support and am awaiting a response:
Juan Doe was on Humana HMO for 3 mos (Jan, Feb, Mar) and enrolled into HUMANA PDP by me for Apr 01 eff date. This should be a pro-rated chargeback for 9 months only per MIPPA guidelines (see below), not a FULL chargeback. MIPPA specifically reads that 3 months on the Plan "is NOT considered a rapid disenrollment". Humana cannot do a complete chargeback on this enrollment without violating these guidelines established by CMS.
120.5.6 - Specific Guidance for Recovering Compensation Payments (Charge- backs)
(Rev. 93, Issued: 06-04-10, Effective/Implementation: 06-04-10)
42 CFR 422.2274, 423.2274
Plans are required to recover compensation payments from agents under two circumstances: 1) when a beneficiary disenrolls from a plan within the first three months of enrollment (rapid disenrollment) and 2) any other time a beneficiary is not enrolled in a plan.
Note: When a member enrolls in a plan effective October 1, November 1, and December 1, and subsequently changes plans effective January 1 of the following year, it is not considered a rapid disenrollment. Therefore, plans cannot charge back agentcompensation payments, If, however, a beneficiary enrolls in October and disenrolls in December, then the plan should charge back because of a rapid disenrollment.
If this is another one of Humana's money saving tricks, it's pretty stupid.
Juan Doe was on Humana HMO for 3 mos (Jan, Feb, Mar) and enrolled into HUMANA PDP by me for Apr 01 eff date. This should be a pro-rated chargeback for 9 months only per MIPPA guidelines (see below), not a FULL chargeback. MIPPA specifically reads that 3 months on the Plan "is NOT considered a rapid disenrollment". Humana cannot do a complete chargeback on this enrollment without violating these guidelines established by CMS.
120.5.6 - Specific Guidance for Recovering Compensation Payments (Charge- backs)
(Rev. 93, Issued: 06-04-10, Effective/Implementation: 06-04-10)
42 CFR 422.2274, 423.2274
Plans are required to recover compensation payments from agents under two circumstances: 1) when a beneficiary disenrolls from a plan within the first three months of enrollment (rapid disenrollment) and 2) any other time a beneficiary is not enrolled in a plan.
Note: When a member enrolls in a plan effective October 1, November 1, and December 1, and subsequently changes plans effective January 1 of the following year, it is not considered a rapid disenrollment. Therefore, plans cannot charge back agentcompensation payments, If, however, a beneficiary enrolls in October and disenrolls in December, then the plan should charge back because of a rapid disenrollment.
If this is another one of Humana's money saving tricks, it's pretty stupid.
