Standards of Professionalism

Policy Number: SLS-003

PURPOSE:

The purpose of this policy is to ensure that Sales Agents adhere to Care N Care’s (CNC) Standards of Professionalism and personal behavior when representing, soliciting and selling CNC Medicare Advantage (MA) products.

In addition, the purpose is to promote the ethical representation of CNC’s Medicare products with the highest level of honesty, integrity, and professionalism.

DEFINITIONS:

Medicare:  The Federal health insurance program for people 65 years of age or older, certain younger people with disabilities, and people with End Stage Renal Disease (ESRD) or Lou Gehrig’s Disease (ALS).

Medicare Advantage (MA):  A Medicare program that allows for more choices among Medicare health plans.  Everyone who has Medicare Parts A & B and resides in the plan’s approved service area is eligible, except those who have End-Stage Renal Disease (ESRD).

Sales Agent:  Licensed insurance agents that are employed by CNC and/or external agents who are licensed, contracted and are certified to sell CNC Medicare Advantage Plans.

Sales Entity:  Field Marketing Organization (FMO), General Agency (GA) or Agency.

POLICY:

CNC follows the Centers for Medicare & Medicaid’s (CMS) requirements contained in Chapter 3 – Medicare Marketing Guidelines (MMG) and in the applicable regulations, in regard to the standards of professionalism.  CNC expects that each Sales Agent who sells CNC MA Plans conduct themselves in a professional manner when interacting with Medicare beneficiaries.  CNC expects that each Sales Agent will assist Medicare beneficiaries to obtain Medicare coverage that best meets their needs and provide a high-quality customer solution for them.

PROCEDURE:

Sales Agents are expected to adhere to the following requirements:

  1. Be prompt for appointments and presentations.
  2. Any unsolicited means of direct contact of beneficiaries is prohibited, including door-to-door solicitation, email or any outbound telemarketing without the beneficiary initiating the contact or giving express permission.
  3. Appropriate business attire is required at all times.
  4. If it is not possible to keep an appointment, a call must be made as early as possible to reschedule with the beneficiary or notify CNC Sales Leadership to assist in rescheduling or reassigning the appointment.
  5. Sales Agents unable to attend a scheduled sales seminar presentation must notify CNC Sales Leadership, at least 48 hours prior the scheduled event, to allow ample time for CNC Sales Leadership to coordinate alternate Sales Agent coverage and provide notification to CNC Compliance for CMS scheduled marketing/sales event reporting.
  6. Sales Agents shall not smoke or use tobacco products when representing, soliciting, or selling CNC Medicare products.
  7. Sales Agents shall not be under the influence of illegal drugs when representing, soliciting, or selling CNC‘s Medicare products.
  8. Sales Agents shall not drink alcohol during working hours on days when they are representing, soliciting or selling CNC’s Medicare products or prior to sales meetings/seminars conducted outside of normal business hours.
  9. Sales Agents shall refrain from using inappropriate language while representing, soliciting, and selling CNC Medicare products.
  10. Upon request, Sales Agents shall produce a photo ID to the prospect; driver’s license is acceptable.
  11. Sales Agents shall provide and leave behind a current business card, or at the very least their contact information, to all Medicare beneficiaries prior to all sales presentations and/or meetings. In addition, Sales Agents shall ensure that any beneficiary requesting an enrollment application also receive any required CMS documents as outlined in the CMS Marketing Guidelines.
  12. “Hard Sell” tactics are never to be employed. The goal is to assist the Medicare beneficiary to enroll in a benefit plan that will meet their needs and provide a positive customer experience during the benefit year.
  13. Sales Agents must electronically acknowledge the Sales & Marketing Code of Ethics during their annual CNC Credentialing and Certification Program.
  14. Sales Agents must comply with the most current Medicare Marketing Guidelines when conducting all sales presentations and/or meetings. The following are prohibited marketing and sales activities and in no way represents an all-inclusive list:
    1. Distributing marketing materials and making verbal statements at all sales presentations and/or meetings that are materially inaccurate, misleading, or otherwise make material misrepresentations.
    2. Misrepresenting themselves, their plans, or the benefits and services covered by their plans.
    3. Claim within their marketing materials that they are recommended or endorsed by CMS, Medicare, or the Department of Health & Human Services (DHHS).
    4. Make statements or imply the following: “endorsed or employed by Medicare”, “calling on behalf of Medicare”, “calling for Medicare”, “Medicare certified”, or that “Medicare recommends that beneficiaries enroll in the plan”.
    5. Use of absolute superlative (e.g., “the best”, “highest ranked’, “rated number 1”) unless they are substantiated with supporting data provided to CMS as a part of the marketing review process.

Sales Agents are regularly monitored to ensure compliant sales and marketing activities.  All non-compliant activities reported to CNC will be investigated and appropriate enforcement activities will be taken in accordance with CNC Policies and Procedures.