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Ok, so since this email was received I've been trying to get to the bottom of if the paragraph noted by the OP truly had any merit or enforceability.
I reached out to CMS and was provided a cookie cutter response:
"QHP issuers participating in the Federally-facilitated Exchange or Federally-facilitated SHOP are responsible for ensuring any delegated or downstream entities, including affiliated agents and brokers, comply with all applicable federal standards and state requirements pursuit to 45 CFR 156.340.
The following links provides resources for agents and brokers in the Health Insurance Marketplaces:
http://www.cms.gov/CCIIO/Programs-a...gents_and_Brokers_QHP_Manual_09102014_508.pdf
Resources for Agents and Brokers in the Health Insurance Marketplaces - Centers for Medicare & Medicaid Services "
In digging into the information provided there is NO mention of not being able to contact clients with info on other products or restrictions on retaining consumer information.
In identifying this as a no answer-answer I called the CMS contact out on that fact. Her final response was: Please direct additional questions to your state DOI or the respective QHP issuer.
Neither QHP provider nor state DOI were involved in the issuance of this "Retaining Consumer Information for Follow-Up with the Marketplace" statement...
I reached out to CMS and was provided a cookie cutter response:
"QHP issuers participating in the Federally-facilitated Exchange or Federally-facilitated SHOP are responsible for ensuring any delegated or downstream entities, including affiliated agents and brokers, comply with all applicable federal standards and state requirements pursuit to 45 CFR 156.340.
The following links provides resources for agents and brokers in the Health Insurance Marketplaces:
http://www.cms.gov/CCIIO/Programs-a...gents_and_Brokers_QHP_Manual_09102014_508.pdf
Resources for Agents and Brokers in the Health Insurance Marketplaces - Centers for Medicare & Medicaid Services "
In digging into the information provided there is NO mention of not being able to contact clients with info on other products or restrictions on retaining consumer information.
In identifying this as a no answer-answer I called the CMS contact out on that fact. Her final response was: Please direct additional questions to your state DOI or the respective QHP issuer.
Neither QHP provider nor state DOI were involved in the issuance of this "Retaining Consumer Information for Follow-Up with the Marketplace" statement...
