Advantage Plus Insurance Agency has formally submitted a comprehensive request to the Centers for Medicare & Medicaid Services (CMS), specifically to the Medicare Drug & Health Plan Contract Administration Group (HPAG), seeking regulatory guidance and standardized safeguards to address growing concerns around Agent of Record (AOR) displacement tied to short-term disenrollment and reinstatement activity within Medicare Advantage plans.

This submission is based on observed and documented enrollment patterns affecting beneficiaries across multiple markets, where individuals are disenrolled often without clear understanding, proper consent, or full awareness of the implications and subsequently reinstated into the same or similar plan within a short time frame, typically within 30 days. In many of these cases, the reinstatement process results in the removal or reassignment of the original Agent of Record, either to a new agent or to a carrier-designated house account.

These occurrences raise significant compliance, ethical, and operational concerns. From a beneficiary perspective, the disruption can lead to breakdowns in continuity of care, including delays or cancellations of prior authorizations, resets in deductibles and benefit structures, interruption of established provider relationships, and administrative instability during active treatment periods. For agents, these patterns undermine the integrity of the advisor-client relationship, diminish accountability, and create an environment where compliant, service-driven practices are at risk of being displaced by short-term enrollment tactics.

The letter outlines several key areas of concern, including the potential circumvention of existing AOR protection frameworks, inconsistencies in how carriers process reinstatement cases, and the risk of incentivized enrollment manipulation. It further emphasizes that current processes may inadvertently conflict with CMS’s broader regulatory intent around beneficiary protections, fair marketing practices, and transparency within the Medicare Advantage program.

To address these challenges, Advantage Plus is advocating for the implementation of a standardized, industry-wide safeguard. The proposed framework recommends that when a beneficiary is disenrolled and subsequently reinstated into the same contract within a defined protection window such as 30 to 60 days the original Agent of Record should remain intact, regardless of whether the reinstatement stems from a complaint resolution, administrative correction, or other qualifying enrollment reversal. This safeguard is not intended to create indefinite agent ownership, but rather to prevent short-term manipulation, ensure consistency in administrative handling, and preserve continuity of care for the beneficiary.

Additionally, the submission reinforces Advantage Plus’s commitment to operating within strict CMS-aligned compliance standards, including adherence to Scope of Appointment (SOA) requirements, beneficiary best-interest obligations, and fair marketing guidelines under applicable federal regulations. The organization has expressed its willingness to provide CMS with supporting case documentation, enrollment data, and real-world examples to assist in evaluating the scope and impact of these issues.

This initiative reflects Advantage Plus Insurance Agency’s broader mission to advocate for sustainable, ethical growth within the Medicare ecosystem. By proactively engaging with CMS and contributing structured, data-informed recommendations, the organization aims to strengthen program integrity, protect the interests of Medicare beneficiaries, and uphold the role of licensed agents as trusted advisors in an increasingly complex healthcare landscape.