Crowe & Associates

Proposed Rule CMS-4205-P

Proposed Rule CMS-4205-P

Proposed Rule CMS-4205-P

Proposed Rule CMS-4205-P

CMS has proposed rule CMS-4205-P which, in the final version will amend the current regulations for Medicare Advantage and Part D programs.  The proposed amendment includes new Medicare marketing and communications policies which would be put in place for the 2025 contracting year starting on September 30th of 2024.  Section 1851(j) of the Act “Enhance Guardrails for Agent and Broker Compensation” is specific to Medicare agents, brokers, agencies and top of hierarchy FMO and NMO organizations.

Note: While the rule changes will have some challenges, Medicare will still be a viable profitable business for individual agents and LOA agencies.  There certainly will be challenges without overrides, HRA fees, expense reimbursements and access to quoting and enrollment platforms at no cost but it can still work. The outlook is not so promising for non LOA agencies that have direct pay agents and rely on overrides for revenue and for top level uplines however.

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How does the rule impact agents and brokers?

The new rule would result in significant changes to Medicare sales distribution.  It would have huge implications on direct pay uplines but would impact producing agents and agencies to a lesser extent. The CMS-4205-P proposal is a 486 page document addressing a number of areas.  Agent compensation is addressed on pages 6 and 236 -248.  Here are the main points regarding section 1851(j)

Eliminate admin fees/overrides:

Marketing reimbursements and HRA fees

Proposed Rule CMS-4205-P is very clear about a number of changes.  Two of them are regarding expense reimbursements to agents and HRA fees:

Proposed rule max allowable commission changes

Other considerations

Accessing Proposed Rule CMS-4205-P (Link to send in comments on the new proposal)

The entire document can be accessed on Regulations.gov    To find the document enter  “CMS-4205-P” into the search bar.  When you go to the document there is a “Comment” button.  CMS is taking comments regarding the new proposal until January 5th.

CLICK HERE TO GO DIRECTLY TO COMMENTS FOR PROPOSED RULE CMS-4205-P

IMPORTANT:  Comments sent in on the proposal are public record so send professional and constructive comments only.  Comments can focus on the value you provide to clients and how not having the services provided by your agency or upline may inhibit your ability to service those clients.  Clients may also send in comments to explain how you work with them to find the best plan options for their situation.

 

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