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Hard Skills and Transition Fills: The Top AEP 2017 Violations

Posted by Nick Bravo on 1/11/17 1:07 PM
Nick Bravo
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During Medicare’s Annual Election Period (AEP), TrendSource Trusted Insight designs and executes secret shop programs for over 30 Medicare Advantage plans, helping companies ensure their sales agents comply with mandated CMS guidelines. Based on more than 4,000 individual projects, we identified the top violation per audit type and, while some have appeared in years past, others were previously unseen. By alerting our clients to these issues, they were able to implement corrective actions. Below, we outline, in no specific order, some of the top AEP 2017 violations.


  • Agents did not delineate the three requirements for Medicare eligibility
  • Agents did not adequately explain the coverage gap or “donut hole”
  • Step Therapy was not clearly or accurately described
  • Agents were not onsite, set up, and ready to begin at the appointed time
  • The presenter did not have at least one copy of the enrollment kit including the Summary of Benefits, Plan Star Ratings, Multi-Language Insert, and Enrollment Form 


  • Agents entirely missed appointments without calling to cancel or reschedule
  • Agents occasionally appeared later than the appointed time
  • Agents did not thoroughly explain the disenrollment period, special election period, and late enrollment penalty

Call Centers

  • In translator call programs, interpreters had some difficulty translating technical terms into and out of English. Difficulties ranged from missing one to two words or entirely mistranslating questions
  • Disconnections occurred at some point during the call
  • Reps occasionally made absolute statements
  • Some reps did not answer hard skills questions with confidence
  • Wait times to reach a live person exceeded 2 minutes

For further insights, stay tuned for TrendSource’s annual AEP In Review blog, coming soon.

Interested in Designing a Robust Compliance  Program for AEP 2018? Click Here to Contact Us

Topics: CMS, Health Care, Healthcare Solutions, CMS Compliance, AEP, Health Care Compliance

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