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From HEAP Commissions to As Earned Medicare Commission

By  Drew Gurley  on August 16, 2025

We have helped numerous independent agents and agency owners navigate the shift off HEAP commission structures to traditional compensation models.

After more than 1 million enrollments, we deeply understand what’s at stake.

Agencies on HEAP often feel trapped by short-term liquidity needs while watching the long-term value of their book disappear.

Our role is to help you get a restart by leveraging your experience and building a business that grows in value.

How to Transition Off HEAP Commissions

Make no mistake, this is not an easy process and requires planning, dedication, and sacrifice at certain levels.  But it’s hard to put a price tag on the end result when you own a thriving business.

We work together like partners

HEAP was certainly the right choice for many agencies at the time, and it’s okay to outgrow anything in pursuit of more.

It provided you critical cash during AEP (Annual Enrollment Period) and helped cover marketing, payroll, and agent commissions. We treat the move away from HEAP not as a failure, but as a milestone in professional development.  We deeply respect the culture you have built and want to reinforce that you should be proud as you take the next step in your business.

HEAP Commissions and Traditional Cash Flow Analysis

Cash is a big, big deal!

We start by mapping your reliance on HEAP commissions versus renewal commissions after your first year on traditional contracts.

  • How much revenue comes from one-time initial commissions?
  • How much are you giving up in long-term value?
  • What are the economics on your customer acquisition costs?
  • What’s the run rate of your cashflow bleed?

This analysis is critical for agencies looking to protect operations while regaining equity.

Our financial models are built to allow us to work together and pull various operational levers to run the scenarios until we find a place that fits what you’re looking for.

Planning the Transition off HEAP

Let’s level set. Most transitions take 18–24 months, but the exact pace depends on your current contracts and exposure.

We work together with you and your team to design a bridge strategy that keeps your agency alive while steadily replacing HEAP income with traditional streams from Medicare Advantage commissions, Medicare Supplement policies, life insurance, and ancillary solutions.

Our goal is to avoid disruption for your team and most importantly, your new book-of-business you’re supporting.  Moving off HEAP commissions is an all hands on deck exercise between our two teams.

Carrier Contract Optimization

If we can, we’ll help you negotiate better carrier commission structures across various MA plans, Medigap, life insurance and ancillary plans such as hospital indemnity and dental and vision. And, in some cases we can help with strategic partnerships that we have developed as an FMO over the years.

Full disclosure, this has become more challenging as other FMOs are willing to operate on unrealistic margins, but our experience allows us to identify sustainable paths forward.  I always encourage agency owners to shop around, but I would urge you to beware of someone willing to work for penny margins.  When push comes to shove and you’re at a point to resolve conflict, the low margin partner will be resentful because they have no profitability in the partnership. Yes, that’s very true.

Optimizing broker compensation ensures you’re aligned with fair market value as defined by CMS’s final rule, and most importantly helps you understand how to navigate the various ways to manage the profitability of your agency.

Education, Support and Onboarding

From webinars to one-on-one planning, we prepare your team for the operational realities of transition.

A good example is expediting the contracting process by deploying a strike team to your office which adds speed and quality in some of the most critical moments of your transition.

They can assist with onboarding into new systems, training on compliance, and ensuring your insurance agents understand how the new compensation rates work for Medicare Advantage plans, Part D plans, and Medicare Supplement business.

We operate as an extension of your brand or stay behind the scenes, whichever best supports your growth strategy.

Connecting With the Right FMO

Finding the right FMO partner is crucial for optimizing agent compensation, managing contract year transitions, and securing additional resources like AHIP training, compliance oversight, and referral programs.

Depending on the level of service you need such as face-to-face geographical support, we can help you get aligned with the right partner.

Transparency is at the center of how we support your growth, so bring us all your questions and we’re happy to role back the curtain to help you make the best decisions.

What About Your Customers During Transition?

This part is painful, but rewarding.

One of the biggest fears for agency owners is disrupting service to their current Medicare beneficiaries during the switch.

As you probably know, the hardest part about this is that HEAP contracts are structured where you don’t own your book of business, which means you cannot take them with you during your transition.  As I stated earlier, there are various levels of pain that come over and this is definitely one of them.

My advice here is to reframe and take your previous experience growing and training a great sales team as the cost of entry to start the next chapter of your career.  You will have a head start on your competition and your speed to scale will be much faster since you’ll have quality levels of hindsight working to your advantage.

Our team will work through this with you, but at the end of the day, you have to respect your contractual agreement.

Why Timing Matters When Leaving HEAP Commissions

You have to stop the bleeding of cash, especially if you are a large organization.

Most agencies only consider leaving HEAP when something forces their hand like a CMS final rule change, or declining compensation rates.

But the truth is, the earlier you start, the stronger your long-term position will be. By slowly reclaiming your book-of-business and renewal commissions, you’ll reduce the initial financial pain.

Pros and Cons of HEAP Commission

Here is a quick look at the pros and cons of heap commission contracts in the Medicare market.

Pros

  • HEAP commissions can provides immediate cash flow during heavy enrollment periods like AEP.
  • Larger initial commissions help cover overhead costs such as marketing, payroll, and agent compensation.
  • Useful for newer agencies expanding into Medicare Advantage plans, Medicare Supplement, or Part D plans.
  • Helps bridge the gap while waiting on delayed carrier payments for initial enrollments, especially during AEP.
  • Proration benefits.

Cons

  • Reduces agency equity and in many cases valuation in the event of an acquisition or sale. Not to say it’s not valuable, it’s just a completely different valuation process and likely buyer profile.
  • Can inadvertently misalign incentives by encouraging aggressive insurance agent sales tactics that don’t always benefit Medicare beneficiaries.
  • Creates dependency on short-term relief instead of stable, recurring revenue.
  • Increasing pressure under CMS final rule changes around MAPD commissions and broker compensation.

Next Steps

In short, we understand many aspects of the HEAP model and the struggle it can be to transition off, especially if you’re a large agency with cashflow needs.

We’re here when you’re ready to talk through your scenarios. Whether you’re in crisis today or preparing for tomorrow, we’ll guide you every step of the way and our experience scaling agencies makes us a uniquely qualified growth partner.

Contact Us Today