Recent CMS Guidance Impacts Humana’s Payment Process
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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 |
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