Compliance with CMS, ACA, and carrier requirements is mandatory. In many cases, violations are treated as "one strike and you're out." Because compliance rules from CMS and carriers are numerous and frequently updated, it is your responsibility to stay current and ensure adherence.
Complaints and Recommended Practices
If a complaint is received from a carrier—whether initiated by a consumer, the Department of Insurance (DOI), or CMS—it is essential that you respond by the deadline set by the carrier. For agencies with five or more agents, we recommend forming a dedicated team to manage these responses.
AOBG is copied on all complaints, either directly or after the carrier has sent it to you. In response, AOBG will "reply all" and include any of your agency's contacts not already copied by the carrier. This may result in duplicate notices.
Common Complaint: Unauthorized Enrollments
The most frequent complaint is that consumers were enrolled without consent. This often occurs when an agent completes the enrollment but uses another agent's NPN as an override, confusing the consumer.
Example Introduction Script
"My name is Joe Smith, and I am the licensed agent assisting you today. My NPN is 123456. You may also see the name [Override Agent Name], who is the principal agent at [Agency Name], with NPN 987654. Please write this down—I can repeat it if needed."
Repeat this at the end of the call as well.
Best Practice Tips
Call Etiquette and Identification
- ✓ State your full agency name at both the beginning and end of every call
- ✓ Avoid using vague names like "Enrollment Center"
- ✓ Introduce all agents involved in the enrollment:
- ✓ Provide your full name and NPN
- ✓ Mention the override agent's name and NPN
- ✓ Clearly state your agency name
Post-Enrollment Communication
- ✓ Send a follow-up email after each enrollment that includes:
- ✓ Your name and NPN
- ✓ The override agent's name and NPN
- ✓ Your agency name and contact information
- ✓ Include this information in your email signature for all ongoing communication
Ongoing Engagement
- ✓ Send periodic emails such as:
- ✓ Birthday greetings
- ✓ Friendly check-ins
- ✓ Avoid including promotional content unless explicitly authorized
- ✓ Send text messages only with client consent
Client Verification & Security
- ✓ Use a "secret word" system during enrollment:
- ✓ Tell clients to ask for a secret word if someone claims to be from your agency
- ✓ Example: "Ask them, 'What is my favorite holiday?' The answer is [Secret Word]. If they don't know it, hang up."
