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AEP 2020 Kickoff: Working Together to Stay Compliant

By  Senior Market Advisors  on October 14, 2019

Ready or not, AEP 2020 is HERE! As we dive in, our compliance team wanted to extend a few reminders. These are some items that are easy to forget through the year but are extra crucial during these next few months.

Dates to be Aware of (When can you Submit an Application)?

First and foremost, please make a note of when you can actually start taking applications: October 15. Even though you can start discussing plan details on October 1, you cannot accept an application or imply to a beneficiary that you can take an application prior to October 15. You cannot encourage a beneficiary to “hold on to” an application until the 15th, either…you must wait! 

What you CAN technically do is leave a blank application with a beneficiary earlier in October, allow them to complete it on their own, and then take it from them on October 15 or later. If the carrier receives an application before October 15, the carrier may investigate to make sure that it was truly beneficiary-completed and not agent-assisted.

AHIP Certification Discount | Senior Market Advisors

Scope of Appointment Guidance

New to the game? Scope of Appointment (SOA) forms are required in Medicare sales. The form establishes what you are permitted to discuss in your client meetings. You are not allowed to discuss items that were not agreed upon in your SOA. Scope of Appointment (SOA) forms should be completed prior to meeting with every potential customer, EVEN IF that customer is already in your book. Every single appointment you attend should have an SOA, because you never know what the client is going to ask about – it’s best to be prepared so that you don’t have to turn around and try again another day!

Additional notes about SOAs:

  • An SOA can be signed hard copy or a telephonic recording
  • If the beneficiary asks to discuss another topic, a new SOA is required
  • Each beneficiary present (even if the appointment was originally for only one person) must sign the SOA
  • SOAs must be submitted with the application, not later
  • You cannot discuss non-health products until at least 48-hours after the MA appointment.
  • Each plan carrier may have additional SOA guidelines, so be sure to check with your contracts for more guidance

Sales Events & Staying Compliant with Carriers

If you plan on conducting any marketing, sales, or educational events, always be sure that you are compliant not only with federal regulations, but also with the carriers.

For example, this year, Cigna released their own “Educational and Marketing/Sales Events Reference Guide,” which states the requirements that you must comply with before you can even host a Cigna-related event. Some of these include being up-to-date on your contracts and certifications and being “in good compliance and performance standing” with Cigna.

Notes on the Application Process

From October 15 through December 7, you may complete the entire “Agent Use Only” section of each application. All applications MUST be received by December 7 to be “counted” for AEP. Failure to submit an application on time may result in delayed enrollment. 

Also, keep in mind that any incorrectly completed applications may result in delayed enrollment. Everything from your NPN to the spelling of the beneficiary’s name needs to be correct on the first submission to ensure a timely enrollment for the beneficiary and an AEP sale for you. 

Medicare Commissions | Senior Market Advisors

When in Doubt

When in doubt about a compliance concern, ask! It helps to belong to a field marketing organization. At Senior Market Advisors, we have our very own in-house compliance team. We’re always available to answer questions and to monitor allegations. If you work with SMA and have any concerns, email