Under the new guidelines, all sales calls with beneficiaries and agents MUST be recorded and retained for 10 years, including enrollment calls.
Because this is so new there are questions that come to mind. Here are just a few:
What constitutes a sales call?
CMS is defining a sales call as any call that is related to the chain of enrollment. So, at this point, a sales call is any call where a beneficiary becomes aware or discusses an MA/PDP plan that can lead to enrollment.
With this definition, this would mean calling leads, scheduling appointments, collecting scope of appointments (telephonically), presenting plans, collecting drug and doctors lists and phone enrollments would all fall under this guidance. In addition, there may be other calls that contain marketing content that would also apply to this new rule and need to be recorded and retained.
Since this rule is brand new, as we get closer to AEP we will learn more from CMS, AHIP, and the plans as to interpretation and implementation to the above information.
How can I record and store calls?
Since many of these calls will contain sensitive HIPAA protected information, we will all need to develop a process for sorting and storing the calls either on a local encrypted drive or a HIPAA compliant cloud-based solution.
If you currently use a VOIP (Voice Over Internet Phone) system, we recommend reaching out to your provider to see if they offer call recording.
In addition, we are currently researching other options for agents to record and compliantly store this data, so stay tuned on our findings!
I use my cell phone. How can I handle this new change?
Most VOIP services have a mobile app version that would allow calls to be recorded from your mobile device.
There are also other companies that make Apps that you can install on your cell phone to record calls.
It’s important to note that there are rules that you must follow when recording phone calls and they may differ State by State.
What about in person appointments?
In person marketing and sales appointments do not need to be recorded. However, the phone calls to set your MA and PDP sales appointments, and any other phone calls discussing benefits or answering questions, would need to be recorded since those would be considered a part of the chain of enrollment.
Servicing questions would not be considered a sales call and therefore would not be required to be recorded.
As we approach the upcoming Annual Election Period, there will be more communication on these new guidelines from health plans and from CMS. We will share important information as we receive it, so stay tuned!
President, Green Leaf – Medicare FMO
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