Disciplinary Action Reporting

TPMO disciplinary action reporting went into effect on 10/1/2022 with the rest of the new rules and regulations. CMS has dictated the following requirements by you and your organizations:

1. You are responsible to collect all disciplinary actions taken for any of your contracted employees/contracted agents and downline agents/agencies.
   AND
2. You must disclose any subcontracted relationships. Examples include marketing, sales, and compensation for lead generation.

Violations & Disciplinary Actions

Not all carriers have given their exact requirements. For example, Aetna is requiring the reporting to be done monthly on the 15th of every month, (starting 11/15/22). Cigna is also asking for monthly data.  

Some examples of Aetna’s violations with Medicare beneficiary interactions include, (but are not limited to):

• Enrolled with no consent
• Illegal behavior
  Example(s): theft from a Medicare beneficiary, stealing a beneficiary. protected health information, and/or acts of violence toward a Medicare beneficiary.
• Fraud
  Example(s): forging a beneficiary signature on an enrollment application, and/or receiving kickback payments.
• High-pressure sales tactics
• Non-compliance with CMS marketing guidelines
  Example(s): conducting cold calling or door-to-door solicitation, and/or providing cash or cash equivalent gifts.
• Egregious behavior
  Example(s): knowingly providing inaccurate information only to entice a beneficiary to enroll in a plan, and/or threatening or abusive behavior.
• Unethical behavior
  Example(s): violations of Aetna’s and/or organizations’ Code of Conduct/Ethical Standards.
• Non-compliance with CMS enrollment guidelines
  Example(s): using invalid Special Enrollment Periods, and/or not obtaining an electronic or paper beneficiary signature.

Some examples of Aetna’s disciplinary actions include. (but are not limited to):

• Verbal warning(s)
• Written warning(s)
• Suspension of agent activities
• Formal retraining
• Formal performance improvement plan
• Termination of agent employment

Where does Pinnacle Fit?

Pinnacle Financial Services is a full-service “FMO” that is dedicated to helping agents across the country both grow and retain their book of business. We are here to help you navigate through all of the rules and regulations, all while staying compliant and maximizing your sales. Don’t hesitate to reach out to us today. It is never too late to make some sales!

For more details visit our website TPMO page.

Need leads in a hurry? Check out our Lead Star Program.