FMOadvisor
Expert
- 48
The new rules dropped yesterday and I am copying the most interesting paragraphs below. Here is my admittedly optimistic reading of this rule.
1. Agents will get a $100 increase in both MAPD and PDP commissions and CMS is anticipating adding an additional 2.5% on top of that. Commissions will be raised to $726 for MAPD for most states, and PDP's will have a massive increase to $200.
2. The new rule specifically states:
This proposal, and all agent broker compensation rules at §422.2274(d) are
limited to independent agents and brokers, and do not extend to TMPOs more generally.
I am curious, is anyone as optimistic as me about the new rules? We do not get volume based enrollment bonuses from our NMA or the carriers and I have many levels under my FMO (SGA's, MGA's, GA's) I don't think this rule applies to overrides paid to them. I believe the rule is targeting HRA fee's and other administrative fee's such as some carriers paying you to get a clients email address, or paying a bonus if you select a PCP on an app. It also seems to be targeting "per app marketing money" that some carriers are paying outside of the override structure. I hope this is true. Read it and let me know what you think:
We believe that increasing the FMV rate for new enrollments by a total of $100, and
therefore applied to renewals at a maximum amount of 50 percent of the total compensation
amount, should provide agents and brokers with sufficient funds to continue to access necessary
administrative tools and trainings, to offset appointment fees and encourage the representation of
multiple plans, and therefore to continue providing adequate service to Medicare beneficiaries.
Accordingly, based on the information provided in comments and for the reasons discussed in
this final rule, we are finalizing a policy to make a one-time $100 increase to the FMV
compensation rate for agents and brokers for initial enrollments into MA plans for the 2025 plan
contract year.
TABLE FC-1: AGENT BROKER COMPENSATION UPDATES CY 2024–2026
2024 2025 2026
Initial Enrollment $611 (FMV TBD) + $100 FMV TBD
Renewal $305 (FMV TBD +100)*0.5 FMV TBD*0.5
By way of example, if we were to assume that the FMV increase in years 2025 and 2026 is 2.5
percent, the payment rates for those years would be as follows:
TABLE FC-2: EXAMPLE AGENT BROKER COMPENSATION UPDATES
CY 2024-2026
2024 2025 2026
Initial Enrollment $611 $726 $744
Renewal $305 $313 $372
Comment: Several comments expressed confusion about whether this payment is an “all in cap” that is intended to include all fees paid by an MA organization to an agent, broker, or
other TPMO, and what that would mean for payments related to marketing activities.
Response: This proposal, and all agent broker compensation rules at §422.2274(d) are
limited to independent agents and brokers, and do not extend to TMPOs more generally.
Therefore, this policy represents a limitation on payments in excess of those paid under
“compensation” only for commissions paid for enrollments to independent agents and brokers.
Though we are continuing to consider future rulemaking in this space, our current policy does
not extend to placing limitations on payments from an MAO to a TPMO who is not an
independent agent or broker for activities that are not undertaken as part of an enrollment by an
independent agent or broker.
1. Agents will get a $100 increase in both MAPD and PDP commissions and CMS is anticipating adding an additional 2.5% on top of that. Commissions will be raised to $726 for MAPD for most states, and PDP's will have a massive increase to $200.
2. The new rule specifically states:
This proposal, and all agent broker compensation rules at §422.2274(d) are
limited to independent agents and brokers, and do not extend to TMPOs more generally.
I am curious, is anyone as optimistic as me about the new rules? We do not get volume based enrollment bonuses from our NMA or the carriers and I have many levels under my FMO (SGA's, MGA's, GA's) I don't think this rule applies to overrides paid to them. I believe the rule is targeting HRA fee's and other administrative fee's such as some carriers paying you to get a clients email address, or paying a bonus if you select a PCP on an app. It also seems to be targeting "per app marketing money" that some carriers are paying outside of the override structure. I hope this is true. Read it and let me know what you think:
We believe that increasing the FMV rate for new enrollments by a total of $100, and
therefore applied to renewals at a maximum amount of 50 percent of the total compensation
amount, should provide agents and brokers with sufficient funds to continue to access necessary
administrative tools and trainings, to offset appointment fees and encourage the representation of
multiple plans, and therefore to continue providing adequate service to Medicare beneficiaries.
Accordingly, based on the information provided in comments and for the reasons discussed in
this final rule, we are finalizing a policy to make a one-time $100 increase to the FMV
compensation rate for agents and brokers for initial enrollments into MA plans for the 2025 plan
contract year.
TABLE FC-1: AGENT BROKER COMPENSATION UPDATES CY 2024–2026
2024 2025 2026
Initial Enrollment $611 (FMV TBD) + $100 FMV TBD
Renewal $305 (FMV TBD +100)*0.5 FMV TBD*0.5
By way of example, if we were to assume that the FMV increase in years 2025 and 2026 is 2.5
percent, the payment rates for those years would be as follows:
TABLE FC-2: EXAMPLE AGENT BROKER COMPENSATION UPDATES
CY 2024-2026
2024 2025 2026
Initial Enrollment $611 $726 $744
Renewal $305 $313 $372
Comment: Several comments expressed confusion about whether this payment is an “all in cap” that is intended to include all fees paid by an MA organization to an agent, broker, or
other TPMO, and what that would mean for payments related to marketing activities.
Response: This proposal, and all agent broker compensation rules at §422.2274(d) are
limited to independent agents and brokers, and do not extend to TMPOs more generally.
Therefore, this policy represents a limitation on payments in excess of those paid under
“compensation” only for commissions paid for enrollments to independent agents and brokers.
Though we are continuing to consider future rulemaking in this space, our current policy does
not extend to placing limitations on payments from an MAO to a TPMO who is not an
independent agent or broker for activities that are not undertaken as part of an enrollment by an
independent agent or broker.