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Update to Agent of Record procedure for individual U65 on exchange

In our recent annual training on individual under-65 on-exchange products, we reviewed the agent of record (AOR) rules as it relates to under-65 application activity and carefully considered feedback from agents, members and other stakeholders. We've made the following revision to our policy. 

What is current process?

The previous or existing agent will remain on the policy regardless of any change activity that may occur outside of the open enrollment period (OEP). During OEP, we refer to this period as the “last one (NPN) in wins.” These procedures were created to help ensure agents were not frivolously removed from one of the many transactions the Federally Facilitated Marketplace (FFM) sends us.

Example:
Time Period: OEP
  1. Agent A is the current agent, but Agent B submits an active re-enrollment to renew or change a current policy. Agent B will become the AOR effective 1/1.
  2. There is no current agent (direct business), Agent A helps an existing member to renew or change their current policy. Agent A will become the AOR effective 1/1.
  3. As a reminder, “passive” enrollment will not change the current AOR.
Time Period: Outside of OEP
  1. Agent A is the current agent, but Agent B works with the policyholder to process an SEP (i.e., adding/removing member, update APTC, change plan, etc.). Agent A will remain the AOR. Agent B can be added during OEP.
  2. There is no current agent, but Agent A works with the policyholder to process an SEP. Agent A will not be added.
What is changing?

Under certain scenarios we will add or replace an agent on a policy resulting from an application received on an existing member outside of OEP.

  • Agents have expressed frustration that when they're asked by an Arkansas Blue Cross policyholder to help process a complex life event (a SEP) outside of open enrollment period the agent helping the member will not be compensated for the work. There were good business reasons meant to protect the AOR from inaccurate and/or frivolous AOR changes. 

Here are the types of transactions/changes by which we will process any AOR change (whichever agent is the NPN on the application received from the FFM).

  • Changing plan types (i.e., change from CSR 87% to 94%)
  • Adding or removing members
  • Financial change – the member needs to update their premium resulting from a change in projected income/federal poverty level percentage
Example:
Time Period: Outside of OEP
  • Agent A is the current agent, but Agent B works with the policyholder to process an SEP (i.e., adding/removing member, update APTC, change plan, etc.). but Agent B works with the policyholder to process one of the above SEP types (i.e., adding/removing member, update APTC, change plan, etc.). Agent B will become the AOR.
  • There is no current agent, but Agent A works with policyholder to process one of the above SEP types. Agent A will become the AOR. (Important note: Internal agents will be treated just like external agents. It is very rare, but if your client requests the help of an internal sales representative to assist with one of the complex SEPs, the current AOR will be removed.
    • The external AOR removed can be added back during OEP.
    • The internal rep will check, prior to helping the member, and explain that they have an external agent that can help them.
    • We'll monitor this new process and make sure everything is fair. We have data that indicates instances like these are extremely rare. You can contact your Arkansas Blue Cross individual products representative if you have specific scenario you’re concerned about.)
  • 3) Agent A is the current agent, a complex SEP is processed without an NPN on the enrollment file received from the FFM. Agent A will remain as the AOR.
  • We know how much work you spend helping service your clients. In some cases, you're not the current AOR but the client trusts and wants you to help. We simply want to make sure you're compensated for this work, and that is why these changes have been made.