Compliance Requirements for Agents with Employees
Do you have employees, interns, temporary workers, or volunteers who help you with your Medicare insurance business? If so, you may need to do the following:
- 1. Provide the employees/interns/temporary workers/volunteers with a Code of Conduct (this can be a carrier’s Code of Conduct, the Berwick Compliance Manual, or your own compliance manual (provided it covers all CMS-required elements))
- • Timeliness: within 90 days of hire & annually thereafter
- • Documentation: signed attestation forms
- • Retention: 10 years plus the end of the current plan year
- 2. Have employees/interns/temporary workers/volunteers complete Fraud, Waste, and Abuse (FWA) and General Compliance training through the Medicare Learning Network (MLN)
- • Timeliness: within 90 days of hire & annually thereafter
- • Documentation: MLN-generated certificates of completion
- • Retention: 10 years plus the end of the current plan year
- 3. Screen employees/interns/temporary workers/volunteers against both the OIG (oig.hhs.gov) and the GSA (sam.gov) databases
- • Timeliness: prior to hire & monthly thereafter
- • Documentation: screenshots of checks (including no-match verification screenshots, if applicable) and a log
- • Retention: 10 years plus the end of the current plan year
Supporting Documents:
Note: If your employees/interns/temporary workers/volunteers are actively contracted with ALL the Medicare Advantage/PDP carriers you are contracted with, you may not be required to complete the actions referenced above; however, certain carriers require that you complete these actions regardless of an employee’s contracting status. For more information, please email compliance@berwickinsurance.com.
Questions? Call 888-745-2320 and ask for Compliance
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