Part D Sales on Med Supps

[somarco]

In the ERISA market if you are a licensed agent and offer advice, even if you are not compensated for that advice, you can be considered a party in interest. If the individual takes your advice and is later dissatisfied, you may be held culpable.

Perhaps the MA/PDP rules aren't as strict.

 

[SportsNut]

Perhaps the MA/PDP rules aren't as strict.

I think in the strictest sense of the word the answer is much simpler than that. In order to even discuss a PDP with a Med Ben you must first have a SOA signed before proceeding. If the discussion takes place otherwise the agent is being non-compliant of CMS guidelines.

I suppose this would only come to light if the client complained and a violation was issued and you were then asked to provide the paperwork that we all keep for 10 yrs. yuk.