Statistically, the number of Humana's MAPD/PDP enrollments that result in an allegation against an agent is just a small fraction of a single percent. The number of allegations that are founded as a result of investigation are just a fraction of allegations themselves, which is outstanding. Here are my root cause reasons for these strong compliance outcomes:
Humana's compliance team has always had great leadership, and the most knowledgeable associates with regard to Medicare Advantage rules and regulations
The initial training requirements of AHIP, Online Pre Work, and Face to Face Classes have required the largest investment of time by agents throughout the industry, but proves that laying that initial foundation sets a precedent for compliance, and helps agents better understand how to avoid issues that may arise.
Evaluating trends and incorporating information about certain trends (scope of appointment details, Pre AEP rules, etc.) are communicated timely, and are included in re-certifcation materials for reinforcement.
Once a carrier gets off track with their compliance outcomes, CMS and perhaps the state DOI's begin to require that all the aforementioned items be revamped, often leading to an excessive amount of re-certification work for the 99% of agents who did not have a founded allegation occur against them. This is a reactive approach that ends up punishing so many agents who have been abiding by the rules all along. I've heard about carriers this year requiring individual testing on 10 different modules...not how an agent wants to spend their summer. Hindsight is always 20/20, but it seems that agents who made the investment in classroom training with Humana, have made up the difference in recertification efficiency over the years, and this summer is no different.