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Medicare Collective
Advisory Council

Each organization was carefully chosen for its unique perspective and product portfolio that fits into the continuum of care solutions.

The Medicare Advisory Council brings together leaders from across the Medicare ecosystem to provide guidance, share insights, and help shape the future of Medicare solutions and the work of the Medicare Collective.

Basic Tenets

Basic Tenets

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Developed by experienced professionals within NAIFA’s Medicare Collective, these basic tenets reflect a shared commitment to ethical marketing, responsible compensation practices, and client-first Medicare planning. Grounded in real-world experience and informed by the evolving regulatory environment, the tenets establish clear standards that protect beneficiaries, uphold the integrity of the agent channel, and reinforce trust in the Medicare marketplace. The tenets are:

  1. Obtaining clear consent to be contacted is essential. Cold calling of any type is not allowed including robo-dialing and artificial intelligence applications.
  2. Internet-based leads should have internet protocol tracking and should never originate from offshore lead generators.
  3. Co-op marketing means Co-op Marketing. Marketing expenses must be actually incurred with co-op covering up to 50% of such expenses. Co-op marketing should not be profit-center for the producer or used as commissions or compensation.
  4. Beneficiary consent should have an expiration date and should not be pursued past the expiration date. Examples of consent include Permission to Contact, Lead Consent and Scope of Appointment.
  5. Commissions must be structured in a manner that emphasizes the client’s needs, discourages churning and encourages servicing the client. Levelized commissions accomplish this while Point of Sale Commission Financing (aka Heaping) and Multi-Year Commission Advancing are transactional and should be avoided.
  6. Agents should use industry-standard software tools that compare multiple options along with approved scripts to ensure plan selection meets the client’s needs.
  7. While a Medicare Advantage product offering may have a variety of attractive extra benefits, agents’ primary focus in plan recommendation should be ensuring limited out-of-pocket expenses for healthcare, in-network access to preferred providers and that drugs are covered by the formulary.

About the Medicare Collective

The NAIFA Medicare Collective was formed to address the growing need for stronger advocacy and representation for Medicare-focused professionals. We educate policymakers, industry leaders, and beneficiaries about the vital role Medicare brokers and FMOs play in delivering quality guidance and maintaining strong compliance standards while helping Americans navigate complex healthcare decisions. Through collaboration and advocacy, we work to protect consumer access to trusted guidance while advancing the integrity and long-term success of the Medicare industry.

Mission and Principles

Mission and Principles

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The NAIFA Medicare Collective was formed to address the growing need for stronger advocacy and representation for Medicare-focused professionals. We educate policymakers, industry leaders, and beneficiaries about the vital role Medicare brokers and FMOs play in delivering quality guidance and maintaining strong compliance standards while helping Americans navigate complex healthcare decisions. Through collaboration and advocacy, we work to protect consumer access to trusted guidance while advancing the integrity and long-term success of the Medicare industry.

The Medicare Collective:

  • Supports insurance and financial professionals specializing in Medicare and healthcare solutions.
  • Provides resources, advocacy, and education to help them navigate the complexities of healthcarerelated products and regulations.
  • Collaborates within the healthcare ecosystem to establish best practices.
  • Informs policymakers based on our firsthand observations, often in the home, with tens of millions of everyday Americans.

The following principles will guide us as broad and enduring guidelines and organizational approaches to consider as we serve our clients. These principles are mutually reinforcing of existing federal, state, and local regulations, as well as the code of ethics upheld by each state’s Department of Insurance.

  1. Client-Centric Service: We will empower the American people with personalized solutions and ongoing support so they can better manage their health and navigate the complex health care system.
    1. Prioritize the needs and goals of clients: ensuring the beneficiary is enrolled in a plan that fits their health needs, financial situation, and personal preferences. The primary focus for brokers in plan selection should consider out-of-pocket expenses, in-network access to preferred providers, and that prescription drugs are covered under the plan’s formulary. Supplemental benefits may also be important to the client, but they must be considered holistically in conjunction with the core benefit structure.
    2. Transparency, accountability, and aligned incentives: Transparency and accountability are essential to maintaining integrity in the Medicare program. Equally important are aligned incentives. Bad actors who employ aggressive sales tactics or circumvent CMS regulations must be identified, retrained, or removed from the system. Such practices erode trust, compromise the accuracy of needs analyses, and disrupt beneficiaries’ care plans—potentially leading to adverse health outcomes.
  2. Compliance and Regulatory Integrity: Compliance sets the standards around quality, which upholds confidence in the Medicare program. The elimination of fraud, waste, and abuse is also a part of compliance and regulatory integrity.
    1. Adhere to CMS rules, HIPAA, and insurance regulations. Specifically, when it relates to broker performance, we should look closely at these five areas: accretion, rapid disenrollment, annual retention, complaints to the health plan, and complaints to Medicare. These five lagging indicators taken together will expose broker opportunism and malfeasance. Carriers independently have immediate access to all this data and can compile and publish lists revealing both the best and worst performers. Some carriers already do this.
    2. Maintain ethical marketing and sales practices. Specifically, carriers should not heap commissions because it circumvents the existing rules around commission payments, incentivizes bad behavior, and does not promote ongoing service of the client.
    3. Collaborate with regulators: Work with NAIC and DOI to help identify, reduce, and eliminate broker malfeasance.
  3. Knowledge and Expertise: We equip beneficiaries with better information by maintaining a deep understanding of Medicare Advantage, Part D, Medigap, and supplemental products.
    1. Implementing known best practices: Known best practices that are leading indicators of quality, such as conducting a 10-day post-enrollment call to confirm that the member received their proof of coverage.
    2. Ongoing broker education: Keeping brokers informed through regular updates on program changes, plan benefits, coverage modifications, and eligibility requirements is essential to maintaining compliance and ensuring accurate guidance for beneficiaries.
  4. Accessibility and Responsiveness: Clients deserve accessibility and responsiveness from both their broker and the overall healthcare system.
    1. Ongoing service and communication: Brokers must maintain ongoing communication with their clients to monitor their experiences when interacting with the healthcare system.
    2. Responsiveness and action: Brokers respond promptly to questions, observations, and other assistance requests. Brokers work with their Broker Resource Integration Organization (BRIO) when they are unable to resolve the situation.
  5. Continuous Improvement: The healthcare industry is rapidly evolving due to unprecedented advances in science, technology, and human behavior. Overall, these forces are creating new models of care, and the broker distribution and service elements must evolve too. Value-based care and personalized medicine are the future direction of healthcare.
    1. Regularly analyze client feedback, retention metrics, and market trends to identify patterns, uncover opportunities, and proactively address challenges in service delivery.
    2. Continuous Process Improvement: Implement process improvements to enhance client experience
    3. Establish a common vocabulary: To effectively collaborate with rule makers, legislators, carriers, and other industry stakeholders, we must establish a shared vocabulary grounded in clear and appropriate definitions. This common language enables us to accurately describe and evaluate the actions, tactics, techniques, procedures, and operations—both desirable and undesirable—within our industry. It also fosters meaningful dialogue among ourselves and with other professionals, enabling us to evolve and adapt our collective body of knowledge, including our guiding principles and core tenets.
  6. Collaboration and Partnership: Healthcare is a team effort and a complicated value stream. We must work together to map out the lifecycle of a beneficiary and define what actions should be taken on that journey, by whom, and to what extent.
    1. Stakeholder collaboration: Work effectively with carriers, brokers, and other stakeholders to improve the beneficiary’s experience and confidence with the Medicare program.
    2. Brokers and BRIOs are an additional resource in a resource-constrained industry: Brokers must be viewed as industry professionals and more tightly coupled into the tools and processes of other industry participants.
  7. Decision-making support tools: Artificial intelligence and other technologies are rapidly evolving to allow new levels of productivity and analytical capability. As we integrate these tools into our workflows, it is essential to use them as decision support systems to enable a human being to perform higher-order tasks, such as building trust and rapport.
    1. Public safety net: Carriers will continue to automate processes, and brokers and BRIOs must serve as a safety net, especially when automation creates barriers to care.
    2. Enhancing Performance Through Data-Driven Tools: Leverage data to develop and deploy decision support tools that improve industry performance and elevate client satisfaction. These tools should empower professionals with actionable insights, streamline operations, and support informed, personalized guidance for beneficiaries.
  8. Consumer Protection: Brokers and Broker Resource Integration Organizations (BRIOs) should work as a single unit to represent beneficiaries when the system does not work for them, specifically:
    1. Guide to Quality: Brokers guide people towards high-quality care and away from low-quality care, which prevents harm to the beneficiary from happening in the first place. Brokers and BRIOs help beneficiaries understand, unlock, and access plan benefits. Evidence of Coverage documents can unintentionally create obstacles to ongoing care, making it difficult for individuals to maintain access to the services they need. Brokers identify and remove barriers that beneficiaries may not be equipped to navigate alone.
    2. Grievances and appeals: There is room for improvement: Despite over 50 million denials annually, only about 11% are appealed. Yet, of those appeals, an impressive 87% are successful.
    3. Additional Resources: Brokers and BRIOs help beneficiaries obtain additional resources available beyond the plan’s benefit structure. For example: Qualify for Medicaid and apply for Medicaid redetermination; apply for state pharmaceutical assistance programs and access community-based resources (such as transportation).
Call Center Gold Standards

Call Center Gold Standards

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Standards for Call Centers and Insurance Carriers Serving Medicare Beneficiaries

  1. Leads are purchased from quality vendors.
    Whether generating leads on their own or through vendors, lead sources should be from trusted sources that will not resell leads to unwitting competitors and compliant language is used. Methods of verification of lead vendors are needed to ensure churn is prevented by only working with respected vendors. Off-shore entities are not acceptable.

    Call centers should track CTMs and accretion rates per-lead source to ensure quality. Relationships with quality vendors, trade groups such as Reach or IMC are advisable.
  2. Operating under Fair Market Value for compensation.
    A number of call centers have received heaped or advanced commissions in a manner which violates the concept of Fair Market Value. In the typical heaped commission approach, the call center receives an advance commission and the agent of record changes to the financing entity. Heaped commissions leave no incentive for the call center to provide service after the sale.

    Insurance carrier compensation should not permit heaped commission directly or through other sources. In addition, there should be no incentives that bias an agent to represent one carrier over another. Rather, the call center should operate in the best interest of the Medicare beneficiary.
  3. Call Centers should have service staff committed to benefit activation and engage the consumer with the product shortly after the sale.
    In addition, call centers should have staff designated to service the consumer and have methods of communication to establish trust and a relationship with the Medicare beneficiary. Retention levels should be above 70% at the end of rapid disenrollment period and the business model should not be acquisition of clients alone.
  4. Call centers should strive for a balanced mix of business.
    Too much emphasis on DSNP attracts a large number of low-income Medicare beneficiaries that have high CTM and low retention rates. Lead generation programs should be diversified to allow more of the non-DSNP population and offer Medicare Supplement, Part D, Medicare Advantage and ancillary coverages.
  5. Call Centers should have recruiting and training methods that ensure continuity of staffing.
    Hiring a class of agents in July and then terming most in January is a sign of broken business model. Notable exceptions would be Business Process Outsourcing on behalf of a carrier and situations where staff are recruited as seasonal staff and are notified of such.
  6. Enrollment emphasis should be placed on filling the insurance need.
    The amount of funds on a food card, extra benefits such as gym membership, etc. should not be focused as the primary reason to enroll. Emphasizing extra benefits over core plan functions is not meeting the purpose of insurance. Agents should verify that drugs are covered, providers are in the network and out-of-pocket expenses are understood by the consumer as vital to reduced CTMs and churn.
  7. Special Enrollment Periods must be documented.
    Abusing Special Enrollment Periods (SEPs) by falsely claiming a qualifying event creates churn and manipulates the consumer. While improved enforcement is needed, honesty and legitimate uses of SEP are best for the consumer and compliant business models for all call centers.
  8. Robust Quality Assurance.
    Applied use of AI to ensure a material number of calls are scored for compliance is highly recommended. Such a system should be supplemented by a compliance team monitoring outputs against prescribed carrier scorecards including tracking CTMs, accretion rates, and retention (beyond the rapid disenrollment period) on a per carrier and per agent basis.

    Contracted call center downline shops should operate transparently so carriers can distinguish them from non-contracted shops and have separately measured performance.

Advisory Council Members

Dr. Darwin Hale
Dr. Darwin Hale

CEO and Founder

Advocate Health Advisors

Bryan M. Keeven
Bryan M. Keeven

President, Health Distribution Product

AmeriLife

Chris Houlihan
Chris Houlihan

Senior Vice President, Business Development

AmeriLife

Rebecca L. Rojas Grimes
Rebecca L. Rojas Grimes

VP, Chief of Staff, Health Distribution

AmeriLife

Cristin Bishop
Cristin Bishop

Chief Operating Officer

The Brokerage, Inc.

Josh Slattery
Josh Slattery

Executive Vice President

The Brokerage Inc.

Steve Kaplan
Steve Kaplan

Chief Legal, Compliance, and Privacy Officer

HealthPlanOne, LLC

Roy Messer
Roy Messer

Chairman

Messer Financial Group

Craig Ritter
Craig Ritter

CEO of Ritter Insurance Marketing and Managing Partner

Integrity

Dwane McFerrin
Dwane McFerrin

Senior Vice President, Med Solutions

Senior Market Sales®

Mark Hunter
Mark Hunter

Chief Distribution Officer

Senior Market Sales®


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For more information, contact Carroll Golden, executive director of the Knowledge Centers, at cgolden@naifa.org.

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