Protecting Beneficiaries. Preserving Accountability.
Advantage Plus Insurance Agency is advocating for stronger federal safeguards that protect Medicare beneficiaries, preserve authorized representation, and create greater transparency throughout the Medicare Advantage enrollment process.
Proposal for a Federal Beneficiary Representation Record
We are asking CMS to establish a standardized and auditable federal record identifying the licensed professional authorized by a Medicare beneficiary to assist with their Medicare Advantage or Part D coverage.
The proposed safeguard would record the Agent of Record within CMS enrollment infrastructure, preserve an audit history of representation changes, and require verified beneficiary authorization before an established representative is replaced.
A stronger system for beneficiary representation and enrollment accountability
Advantage Plus Insurance Agency has formally requested that the Centers for Medicare & Medicaid Services establish stronger and more consistent protections surrounding Agent of Record relationships in Medicare Advantage and Part D.
Our advocacy began with documented concerns involving short-term disenrollments and reinstatements that can unintentionally remove or reassign a beneficiary’s original Agent of Record. We are now proposing a broader federal safeguard: a Beneficiary Representation Record maintained within CMS enrollment systems.
The goal is not to restrict beneficiary choice. Beneficiaries should always remain free to change representatives or choose no representative at all. The goal is to ensure that every change is deliberate, transparent, properly authorized, and auditable.
Understanding the original AOR protection request
This video explains the enrollment patterns that prompted our initial CMS submission and why consistent federal safeguards are important for beneficiaries and the licensed professionals who serve them.
Why the current process needs stronger safeguards
Critical plan enrollment information may be retained while the identity and history of the beneficiary’s authorized licensed representative remains fragmented across individual plan and distribution systems.
Representation Can Be Disrupted
Temporary disenrollments, reinstatements, retroactive corrections, and complaint resolutions may remove or reassign the original AOR.
Beneficiaries May Not Know
A beneficiary may not realize that an enrollment transaction also changed the licensed professional associated with the plan.
Records Are Fragmented
AOR information may be stored differently by each health plan, making oversight and correction difficult.
Unauthorized Changes Are Harder to Detect
Without a standardized federal audit trail, questionable representation changes may be more difficult to identify.
Service Continuity May Be Lost
Beneficiaries can lose access to the individual familiar with their providers, prescriptions, and coverage decisions.
Accountability Should Follow Enrollment
A reliable record should identify the licensed person associated with an agent-assisted enrollment.
What the Beneficiary Representation Record should include
We respectfully request that CMS evaluate the creation of a standardized record within MARx or another appropriate CMS-controlled enrollment system.
Authorized Representative Identification
Record the agent’s name, National Producer Number, writing identifier, agency affiliation, and effective date of representation.
Enrollment Association
Associate the representative with the relevant contract, plan benefit package, enrollment date, effective date, and enrollment channel.
Complete Representation History
Maintain a time-stamped record of each addition, removal, transfer, or replacement, including the initiating entity and reason.
Verified Beneficiary Authorization
Require a CMS-approved method of authorization before an established representative may be replaced, except for defined exceptions.
Protection During Administrative Transactions
Temporary disenrollments, reinstatements, complaint resolutions, premium corrections, and retroactive adjustments should not automatically terminate the record.
Formal Dispute and Correction Process
Establish a consistent procedure for beneficiaries, plans, agents, and agencies to correct inaccurate or unauthorized records.
Role-Based Access and Privacy
Maintain appropriate privacy protections while allowing beneficiaries and authorized entities to confirm the currently recorded representative.
Designed around beneficiaries—not agent ownership
This proposal does not give any agent permanent control over a beneficiary. It creates a record showing who the beneficiary authorized, when the authorization became effective, and whether any subsequent change was properly documented.
“An existing Agent of Record should not be removed or replaced unless the beneficiary is aware of the change, affirmatively consents to it, and the transaction is recorded through an auditable CMS-approved process.”
Beneficiary Protection
Reduce unauthorized or unintended representation changes and improve informed consent.
Program Integrity
Create data that helps identify unusual patterns, repeated switching, and possible abuse.
Continuity of Assistance
Help preserve access to the professional familiar with the beneficiary’s coverage history.
Proposed AOR protection during short-term enrollment disruptions
Our original request asks CMS to create a consistent industry-wide framework for cases in which a beneficiary is disenrolled and then reinstated into the same contract within a defined protection period.
Preserve the Beneficiary Account
Beneficiary accounts should not be deleted for a reasonable protection window. If the beneficiary returns to the same carrier, enrollment records and the original AOR should be restored as appropriate.
Verified Two-Way Consent
A change to an established Agent of Record should occur only after the beneficiary’s informed authorization is verified and documented.
Standardized Reinstatement Handling
Create consistent requirements across Medicare Advantage and Part D sponsors.
No Automatic House-Account Reassignment
Administrative transactions should not automatically erase a valid representative relationship.
Beneficiary Choice Remains Protected
Beneficiaries remain free to select a new representative or choose no representative.
Read our federal safeguard proposals
These submissions present related but distinct recommendations for improving beneficiary protection and Agent of Record accountability.
Federal Beneficiary Representation Record
A proposal to record and preserve authorized beneficiary representation within CMS enrollment systems, with verified consent and a complete historical audit trail.
Open New Federal ProposalAOR Protection During Disenrollment and Reinstatement
A request for standardized safeguards to preserve the original Agent of Record during qualifying short-term enrollment disruptions and administrative corrections.
Open Original CMS SubmissionConstructive advocacy for a stronger Medicare system
Advantage Plus Insurance Agency remains committed to beneficiary best-interest standards, transparent marketing, responsible enrollment practices, and constructive collaboration with CMS, HHS, health plans, regulators, and industry stakeholders.
We welcome the opportunity to provide documented examples, enrollment timelines, technical recommendations, or other information that may assist federal policymakers in evaluating these safeguards.
Help us advance stronger beneficiary protections.
Review the proposals, share the initiative with industry stakeholders, and support transparent, accountable representation throughout the Medicare enrollment lifecycle.