Are you helping clients enroll online into plans without being the agent of record? This is considered a violation. Yes, you read that right, helping your clients use Medicare.gov to enroll into a Part D plan can be a violation.
From UHC’s EDC Agent Guide Version 2.3 Date 2/5/2016 Page 99:
Agents are prohibited from completing the web enrollment on behalf of the consumer or at the consumer’s request. However, an agent may be on the telephone in order to assist the consumer with a web enrollment.
Agents must not be physically present with the consumer when a consumer is completing a web-based enrollment and must not engage in any screen sharing with the consumer through an internet connection (e.g., the consumer gives the agent control of the consumer’s computer to complete a web enrollment via WebEx) unless agreed to by the Vice President of Sales Oversight and the Compliance Officer.
Completing a web enrollment through the web-based enrollment tool on behalf of a consumer may be considered fraud.
According to UHC, this also includes Medicare.gov.
What this means for agents:
If you have a Part C or Part D contract with any carrier, you cannot help clients enroll into a Medicare Advantage (Part C) or Medicare Prescription Drug Plan (Part D) through any consumer facing enrollment website, including Medicare.gov according to compliance experts.
You can be on the phone, but not physically present for the enrollment.
If you do not have a Part C or D contract, we would advise that you follow the same advice as above.