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AEP 2013: Top 7 Violations Identified in Compliance Programs

During the course of last year’s AEP season, we conducted 3,900+ secret shop programs around formal/informal sales events, 1-on-1 appointments and call center audits. Below are the top 7 violations uncovered through our secret shopper compliance programs:

  • Enrollment kits were not provided or kits did not include all of the required items
  • Information on Plan Ratings was not provided or fully discussed
  • Event attendees were required to provide contact information
    • Event sign-in sheets did not clearly state "optional"
  • Election periods were not explained in full
  • It was not explained how to request an exception/transition process applicable to new members of an MAPD or PDP when a drug they are taking is not on the plan formulary
  • Step therapy was not explained
  • Prior authorization was not explained

Although no one wants violations to occur, the secret shop findings allowed the Medicare Advantage/Prescriptive Drug organizations to quickly disseminate the information, update any documents, and ensure agents/brokers are providing a consistent, compliant message.




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