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Required Aetna Compliance Reporting:
Mandatory TPMO Subcontracted Relationship Reporting

By: Chalen Jackson

Aetna recently released a letter outlining how they plan to oversee new requirements set forth by the 2023 Final Rule, specifically, disclosing subcontracted TPMO relationships. All agents are required to submit the form provided by Aetna prior to 11/15/2022, and upon starting or discontinuing any subcontracted relationships after that. 

Disclosures are required for any relationships that are being compensated to perform any activities related to marketing, lead generation, or enrollment activities. These relationships may include, but are not limited to:

  • Lead companies
  • Marketing companies
  • Social Media Management
  • CRMs that include marketing functions
  • Virtual assistants
  • Appointment setters
  • Non-licensed staff that process applications

Agents are required to file any current relationships by 11/15/2022 and going forward must file within 30 days of terminating any applicable relationships or beginning any new relationships. The form needs to be completed for EACH vendor/subcontracted relationship. 

Even if you do not currently have any relationships to declare, you must fill out the form to indicate that you do not have any relationships to declare. 

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