Recent CMS Guidance Impacts Humana’s Payment Process

2016-03-30 // News

**The following information is from Humana. If you have any questions, please contact AMAC Broker Services at 1-888-776-6565 or via email at **[email protected]

**Or contact Humana at [email protected].     **

Amendments to contracts containing information about The Centers for Medicare & Medicaid Services’ (CMS) recently issued updated guidance regarding when an agent should be paid full or pro-rated initial year compensation were sent in November 2015 to Humana’s contracted agencies. **For your reference, we’ve included the updated CMS guidance below: **

There are three scenarios affecting how an organization may pay full or pro-rated initial compensation.

- For a beneficiary's first year of enrollment in a plan, in which the MARx report lists the prior plan type as "none," organizations may pay full or pro-rated initial compensation.

- When a beneficiary moves from an employer group to a non-employer group plan, in which the MARx report lists the prior plan type as "none," organizations may pay full or pro-rated initial compensation for a beneficiary's first year of enrollment in a plan.

- For unlike plan changes (e.g., MA-PD to PDP or PDP to Cost Plan), occurring after January 1 in which the MARx report indicates the beneficiary had prior plan history (regardless of plan type), organizations must pay pro-rated initial compensation according to the number of months in the plan. For example, a change from a PDP to an MA-PD effective May 1 is an unlike plan change resulting in a pro-rated initial compensation of 8/12 (May thru December) of the MA-PD initial compensation rate.

For further clarification, the chart below is a brief summary of how the new CMS guidance will affect payments:

Type of Enrollment** (as indicated on the CMS MARx report)** Description Humana Commission Payment

Initial Sale (prior plan type listed as “none” on MARx report) New enrollment (i.e. age-in, new to Medicare, or enrolls from original Medicare) Full Initial Sale commission

Unlike Plan Type Change (prior plan history indicated on MARx report) PDP only to MA or MAPD or MA or MAPD to PDP only Initial Sale commission will be pro-rated based on the number of months the member will be enrolled in the plan.

Employer group plan to a non-employer group plan when MARx report indicates prior plan type as “none” Group plan to individual plan Full Initial Sale commission