PRODUCER PARTNERSHIP PLAN - PDF Free Download

PRODUCER PARTNERSHIP PLAN MarketPOINT Delegated Agents and Agencies Applicable to Medicare Advantage and Prescription Drug Plans 2013 Plan Year 0

Table of Contents Section I - MA and PDP Sales and Marketing Agreement.2 Section II - Code of Ethics 8 Section III - Commission Schedules ; 12 Section IV - Policy on Plan and Product Changes.. 23 Section V - Minimum Business Production Standards 25 Section VI - Policy on Agent Release from MGA or Humana Independent Channel 26 Section VII - Managing General Agency Expectations...29 Section VIII - GPA Contract Amendment. 32 1

Section I MA & PDP Sales and Marketing Agreement A. Training and Certification Requirements to sell Humana Medicare Advantage (MA) plans and Prescription Drug Plans (PDP) A Group Producing Agent (GPA) is required to participate in training specified by Humana MarketPOINT and pass a certification test in order to be authorized to sell Humana MA or PDP plans. GPAs may only sell the MA or PDP plans for which they have successfully completed the Company-required training and passed the Company-required certification. Passing scores for training are as follows: Humana required AHIP training 90% Humana specific training 85%. The GPA must be recertified for each type MA and PDP plan on an annual basis thereafter in order to be authorized to sell the respective type MA or PDP plan. Recertification consists of annual training and testing, generally in late Summer or early Fall prior to the Annual Election Period. Passing scores are as stated above. The GPA may not present or sell an MA or PDP or otherwise represent for a MA or PDP product after the Humana certification/recertification, state license or Company appointment has expired. The GPA and Managing General Agency (MGA) will forfeit all new and renewal agent and/or override commissions on any MA and PDP plans without the applicable valid licensing, appointment and certification on file with Humana at the time of the sale or renewal. It is the GPAs responsibility to ensure that the GPA has met all Humana training and certification requirements and testing. B. Sales and Marketing The GPA and MGA must comply with all Centers for Medicare and Medicaid Services (CMS) regulations and requirements, the GPA Contract Amendment, the GPA Medicare Advantage Plans and Prescription Drug Plan Sales and Marketing Agreement, GPA Medicare and Free Standing Benefit Commission Schedule, and the Producer Partnership Plan, including any subsequent amendments. C. Discrimination Based on Health Status It is a violation of CMS requirements and regulations and is strictly prohibited to discriminate against any Medicare eligible prospect for enrollment in an MA or PDP plan based upon an applicant s health status, except as permitted by CMS. The GPA is prohibited from asking for or attempting to obtain any personal medical information regarding an applicant when specifically discussing a Humana MA plan(s) or PDP plan(s). Any personal medical information that may be obtained on an applicant as a result of discussion or through application for any other insurance product can in no way be used to discourage the applicant s enrollment in a Humana MA or PDP plan. D. Gifts or Payments to Induce Enrollment The GPA may neither give nor offer a gift, meal or payment of any kind to a prospective MA or PDP member as an inducement to enroll in an MA or PDP plan. Additionally GPAs may neither give nor offer a gift, meal or payment of any kind to a current MA or PDP member as an incentive for any sales made from referrals provided by the member. An offer of a rebate in any form is strictly prohibited. Door prizes, etc., to be given away at professional seminars, and the like, which are intended to promote the MA or PDP products, must be of nominal value, and cannot be readily converted to cash. CMS defines nominal value as $15 retail or less. Names drawn for a raffle prize must be randomly chosen and winners must not be dependent upon enrollment or agreement to a presentation of the plan. 2

Section I MA & PDP Sales and Marketing Agreement (continued) E. Use of Recruiting & Marketing Literature/Member Communications GPAs are required to comply with all CMS requirements and regulations regarding the marketing and sale of an MA or PDP product. CMS requires that all marketing materials or communications to prospective and current members meet certain criteria and be filed and approved by CMS prior to their use. CMS guidelines are updated periodically and it is the responsibility of the GPA and MGA to be aware of and comply with any and all requirements. CMS publication entitled CMS Medicare Managed Care Manual, Chapter 3 Marketing can be found on the CMS website. GPAs are required to monitor the CMS website and any other website on which CMS may now, or in the future identify applicable requirements. All marketing, advertising, recruiting or member communication literature regarding Humana or Humana MA or PDP plans must be reviewed and approved by Humana and, as appropriate, CMS in advance of use by any GPA. Marketing literature and member communication includes, but is not limited to, any material prepared for written, audio, or electronic media use (TV, radio, newspaper, magazine, Internet, etc.) as well as any advertisements, brochures, letters, mailers, handouts, posters, telemarketing scripts, sales kit material, door knob hangers, fliers, referral questionnaires, yellow page advertisement, flip-charts, greeting cards, recruiting letters, etc., to be used for either prospect gathering, enrollment purposes, agent or member communication. Failure to comply with this requirement will result in the termination of the GPA as applicable. The GPA may use approved materials to market to their book of business, however, any marketing outside of their current book of business along with the materials to be used for that marketing must be approved first by the Delegated Sales Director and area Humana MarketPOINT Sales Director. Any marketing material using the Humana name for purposes of recruiting agents, must be approved first by the Delegated Sales Director. In addition, all persons, e.g., office staff, etc including GPA not directly involved in the sale of products, must abide by this requirement. F. Sales Presentation and Statement of Understanding All GPAs are provided a copy of the CMS-approved Humana Sales Presentation Book and are required to use it in its entirety whenever presenting the Humana MA or PDP plan(s). The use of the standardized Sales Presentation Book ensures that all prospects consistently receive the same information from which they can make well-informed decisions regarding enrollment in a Humana MA or PDP plan. The Sales Presentation Book contents guarantee full disclosure of all key features of the plan to prospective enrollees. During each sales appointment the GPA representing the plan must: Discuss only the plans that were agreed to during the Scope of Appointment process Review and leave the Sales Brochure with the beneficiary Review and leave the Summary of Benefits with the beneficiary The Statement of Understanding, as it appears on the enrollment application, is a key component of the enrollment process and one that must be presented in a comprehensive manner. GPAs agree to do so each time they enroll a prospective member in a Humana MA or PDP plan. CMS requires that certain disclosures be provided to all beneficiaries, in writing, during a sales presentation. GPAs are therefore required to distribute those disclosures, as applicable, to all beneficiaries they present Humana MA and PDP plans to. At all PFFS appointments, you must determine which of the two possible disclaimers applies and must either verbally read or state the applicable PFFS disclaimer. In addition, the PFFS leaflet must be given to each prospect. 3

Section I MA & PDP Sales and Marketing Agreement (continued) PFFS Disclaimers For non-network PFFS plans: A Medicare Advantage Private Fee-for-Service plan works differently than a Medicare supplement plan. Your provider is not required to agree to accept the plan s terms and conditions of payment, and thus may choose not to treat you, with the exception of emergencies. If your provider does not agree to accept our terms and conditions of payment, they may choose not to provide health care services to you, except in emergencies. If this happens, you will need to find another provider that will accept our terms and conditions of payment. Providers can find the plan s terms and conditions of payment on our website at: http://www.humana-medicare.com/medicare-advantage-plans/humana-goldchoice-terms-conditions.asp" For full network PFFS plans: A Medicare Advantage Private Fee-for-Service plan works differently than a Medicare supplement plan. We have network providers (that is, providers who have signed contracts with our plan) for all services covered under Original Medicare. These providers have already agreed to see members of our plan. If your provider is not one of our network providers, then the provider is not required to agree to accept the plan s terms and conditions, of payment, they may choose not to provide health care services to you, except in emergencies. If this happens, you will need to find another provider that will accept our terms and conditions of payment. Providers can find the plan s terms and conditions of payment on our website at: http://www.humana-medicare.com/medicare-advantage-plans/humana-goldchoice-terms-conditions.asp. For partial network PFFS plans: A Medicare Advantage Private Fee-for-Service plan works differently than a Medicare supplement plan. We have network providers (that is, providers who have signed contracts with our plan) for durable medical equipment, home health providers, and some freestanding labs and hospitals. These providers have already agreed to see members of our plan. If your provider is not one of our network providers, then the provider is not required to agree to accept the plan s terms and conditions, of payment, they may choose not to provide health care services to you, except in emergencies. If this happens, you will need to find another provider that will accept our terms and conditions of payment. Providers can find the plan s terms and conditions of payment on our website at: http://www.humana- medicare.com/medicare- CMS may elect to require additional beneficiary disclosures in the future, and GPAs will be responsible for their distribution in addition to those already defined herein. G. Marketing Through Unsolicited Contacts CMS strictly prohibits door-to-door solicitation for the purpose of solicitation or obtaining prospects names for enrollment in a Humana MA or PDP plan. Additionally, CMS rules state that agents may not send emails to beneficiaries regarding Humana MA or PDP plans, unless the beneficiary has provided his/her e-mail address. The prohibition on door-to-door solicitation extends to other instances of unsolicited contact that may occur outside of advertised sales or educational events. Prohibited activities include, but are not limited to, the following: Outbound marketing calls, unless the beneficiary requested the call. This includes contacting existing members to market other Medicare products, except as permitted below. Calls to former members who have disenrolled, or to current members that are in the process of voluntarily disenrolling, to market plans or products, except as permitted below. Calls to beneficiaries to confirm receipt of mailed information, except as permitted below. 4

Section I MA & PDP Sales and Marketing Agreement (continued) Calls to beneficiaries to confirm acceptance of appointments made by third parties or independent agents. Approaching beneficiaries in common areas (i.e. parking lots, hallways, lobbies, etc.) Calls or visits to beneficiaries who attended a sales event, unless the beneficiary gave express permission at the event for a follow-up call or visit. GPAs and the Company may do the following: Agents who enrolled a beneficiary in a plan may call that beneficiary while they are a member of that plan. Call beneficiaries who have expressly given permission for a plan or sales agent to contact them, for example, by filling out a business reply card or asking a Customer Service Representative (CSR) to have a GPA contact them. This permission applies only to the entity from whom the beneficiary requested contact, for the duration of that transaction, or as indicated by the beneficiary. CMS views that that permission to contact may not be treated as open-ended in duration and should be considered short term and event specific generally 90 days (e.g. AEP, OEP, etc) Agents are advised to keep detailed records regarding beneficiaries who have given permission to be contacted. Conduct outbound calls to existing members to conduct normal business related to enrollment in the plan, including calls to members who have been involuntarily disenrolled to resolve eligibility issues. Call former members after the disenrollment effective date to conduct disenrollment survey for quality improvement purposes. Disenrollment surveys may be done by phone or sent by mail, but neither calls nor mailings may include sales or marketing information. Under limited circumstances and subject to advance approval from the appropriate CMS Regional Office, call Limited Income Subsidy (LIS) eligible members that a plan is prospectively losing due to reassignment to encourage them to remain enrolled in their current plan. All outbound calls require an approved script or talking points and all scripts must be submitted for review and approval by the Company and CMS prior to use in the marketplace. When conducting outbound calls: Scripts must include a privacy statement clarifying that the beneficiary is not required to provide any information to agent and that the information provided will in no way affect the beneficiary s membership in the plan. The Company (and a GPA) are prohibited from requesting beneficiary identification numbers (e.g., Social Security Numbers, bank account numbers, credit card numbers, HICN). The Company (and a GPA) are NOT allowed to say they are contracted with Medicare to provide prescription drug benefits or that they are Medicare-approved MA-PD/PDP. The Company (and a GPA) cannot use language in outbound scripts that imply that they are endorsed by Medicare, calling on behalf of Medicare, or Medicare asked them to call the member. H. Cross-selling Beneficiaries already face difficult decisions regarding Medicare coverage options and should be able to focus on Medicare options without confusion or implication that the health and the non-health products are a package. The following rules apply: GPAs are prohibited from marketing non-health care related products (such as annuities and life insurance) to prospective enrollees during any MA or Part D sales activity or presentation. GPAs may sell non-health related products on inbound calls when a beneficiary requests information on other non-health related products. 5

Section I MA & PDP Sales and Marketing Agreement (continued) Marketing to current plan members of non-ma plan covered health care products, and/or nonhealth care products, is subject to Health Insurance Portability and Accountability Act (HIPAA) rules I. Appointment Setting To ensure beneficiaries have accurate information to make an informed choice about their Medicare benefits without being pressured, marketing representatives must: Clearly identify and inform the beneficiary of all products that will be discussed prior to the inhome appointment. (Examples of separate lines of business include Medigap, MA, and PDP) The beneficiary must agree to the Scope of the Appointment (SOA) and that agreement must be documented by the plan. It can be documented by a digitally recorded call through the agent IVR line or in writing using the Scope of Appointment form. Documentation of SOA must be collected by the agent prior to the appointment taking place. Agents and organizations that contact a beneficiary in response to a reply card may only discuss the products that were included in the advertisement. Additional products may not be discussed unless the beneficiary requests the information. Any additional lines of plan business that are not identified prior to the in-home appointment via the Scope of Appointment documentation process can be discussed as long as the beneficiary requests it and a new Scope of Appointment form is completed identifying the additional plans. The SOA can be executed at the beginning of the appointment under the following circumstances: Beneficiary walks into the office - complete SOA form or IVR prior to beginning presentation and notes that it is a walk-in During a scheduled appointment an unexpected beneficiary asks to sit in - complete SOA form or IVR prior to beginning presentation Beneficiary request to hear additional information regarding a plan that was not on the original SOA complete a new SOA form or IVR identifying additional plans prior to discussing additional plan It is unfeasible for the agent to obtain a paper SOA or IVR recorded SOA before the scheduled appointment. J. Educational Events CMS has clarified that the purpose of educational events is to provide objective information about Medicare programs/and/or health improvement and wellness. Educational events should not be used to steer or attempt to steer a beneficiary towards a specific or group of plans. Consider the following when conducting an educational event: Sales activities including the distribution of marketing materials or the collection of plan applications is prohibited Advertising material for educational events must include the disclaimer educational only and information regarding the plan will not be available Education events should be promoted to be educational in nature, may have multiple vendors, and may be sponsored by the plan(s) or by outside entities (i.e. health fairs, conference expositions, state or community sponsored events) 6

Section I MA & PDP Sales and Marketing Agreement (continued) K. Prohibition of Meals Medicare Advantage and Prescription Drug plans or their representatives may not allow prospective enrollees to be provided meals, or have meals subsidized, at any event, seminar or meeting at which plan benefits are being discussed and/or plan materials are distributed. GPAs are allowed to provide refreshments and light snacks to prospective enrollees. Refreshments and snacks should not be bundled in an attempt to provide a meal. L. Agent Licensing, Appointments and Terminations The Company must comply with the State licensing and appointment laws that require plans to give the state information about which agents are marketing part C and D plans. Humana requires a state licensed and appointed representative when there is marketing activity involved, which is defined as steering, or attempting to steer, a potential enrollee towards a plan or group of plans, and for which the individual or entity performing marketing activities expects compensation directly or indirectly from the plan for such marketing activities. In addition, Part C and D sponsors must report the termination of any agent or broker, and the reasons for the termination, to the state in which the agent or broker has been appointed in accordance with state appointment laws. A GPA must hold a valid health license and Humana appointment for the Humana subsidiary or affiliate offering the MA or PDP plan in any state that the beneficiary resides in and where the GPA sells or solicits MA and PDP plans on behalf of the Company. GPAs are reminded that they must be licensed and appointed in the state where the beneficiary resides, regardless of where the sale takes place. If it is determined that a GPA engaged in or asked another individual or entity on his/her behalf to engage in improper telemarketing, cold-calling, door-to-door solicitation, or other actions not permitted under the GPA Contract Medicare Amendment and GPA Medicare Advantage Plans and Prescription Drug Plan Sales and Marketing Agreement and this Producer Partnership Plan, or not permitted under applicable law, Humana, at its sole discretion, may terminate the GPA s Medicare Advantage and/or Prescription Drug Plan eligibility under the Group Producing Agent/Agency Contract or terminate the Group Producing Agent or Agency Contract in its entirety. 7

Section II Code of Ethics As a leader in Medicare Advantage (MA), Prescription Drug (PDP) plan and Medicare Supplement business, Humana is committed to providing appropriate guidance to its valued customers. Our company s continued success depends upon the integrity of all persons representing us. Each sales agent will subscribe to the following Code of Ethics, applicable to the sale of Humana MA, PDP and Medicare Supplement (Medigap) plans. In addition, agents agree to comply with, all Centers for Medicare and Medicaid Services (CMS) and state Department of Insurance (DOI) regulations, as well as Humana MarketPOINT policies as an expression of personal commitment to honest and ethical sales and marketing practices. The Code of Ethics is reviewed annually during the recertification process at which time you are asked to review and sign that you understand the agreement. Your signature acknowledges that commitment and that you have read each item and agree to comply with its content. Violation of this Code may subject you to termination and/or possible legal action as specified by CMS and/or State regulations. 1. Agents will conduct themselves with professionalism and integrity and with respect for the rights and reasonable requests of prospective customers at all times. 2. Agents will disclose their name and their agency name at the start of every appointment and will provide all clients a business card that identifies them. In addition, they will clearly disclose at the onset of the appointment the purpose of their visit and the products to be discussed. They will make no claim other than to explain the appropriate Humana products, their benefits, limitations, the offering company and how to enroll/apply. Misrepresentation of the purpose of the agent s visit is strictly prohibited. 3. During a presentation of MA/PDP products agents will discuss only those plans as agreed to in the Scope of Appointment in advance of the appointment. Medigap alone does not require a Scope of Appointment. If a situation arises and it is not feasible to secure prior to the appointment, the agent must provide a reason on the Scope of Appointment form. This should be the exception, not the rule. Agents are only permitted to present other health related products such as Dental, Vision, etc. in conjunction with a MA/PDP product discussion. Agents cannot engage in cross selling any non-health related products at the same appointment for MA/PDP plans. 4. Agents agree to use the CMS-approved Humana Sales Presentation in its entirety, to include the Summary of Benefits, and in order of the PowerPoint / flipbook when presenting a Humana MA and/or PDP plan to ensure full disclosure of all plan benefits, limitations, and cost sharing to all prospective enrollees and will present all required CMS disclaimers during the sales presentation. Agents will not modify or alter approved materials for their use in marketing/sales of MA and/or PDP plans. 5. Agents will base their presentation of the Humana MA / PDP / Medigap plan on the merit of the respective plan and will not disparage competitors or their plans. 6. Agents will make only approved claims as authorized by Humana and CMS and shall use no forms of pressure, scare tactics, coercion, deception, sympathy, appeal, or other unethical sales tactics in their presentation. 8

Section II Code of Ethics (continued) 7. Agents will always give clear, thorough and accurate information regarding Humana MA, PDP and Medigap plans. They are prohibited from making false, misleading, half-true, or exaggerated statements. 8. Agents understand that it is a violation of CMS regulations and is strictly prohibited from discriminating against any Medicare eligible prospect for enrolling in a Medicare Advantage (MA) and/or Prescription Drug (PDP) plan based upon their health status, except as permitted by CMS. Any personal information obtained about a prospect as a result of discussion/application for any other product distributed by Humana MarketPOINT will in no way be used to discourage their enrollment in a Humana MA and/or PDP plan. Additionally, any such personal information will be treated in full accordance with all HIPPA regulations regarding use of personal information, 9. Agents are aware of and will abide by all laws pertaining to the Do Not Call Registry. 10. Agents understand that only a competent enrollee or their appropriate legal designee, as stipulated by CMS, can sign an enrollment application. Agents will not sign the enrollee s name, with or without their permission, on the enrollment application or knowingly accept a signature other than the enrollee s on an application for any product, except in the case of an authorized POA. They will not knowingly accept a signed incomplete application. 11. Agents are responsible to ensure that all information on an MA, PDP or Medigap application is complete and accurate and will not alter, remove, replace or misrepresent any information obtained from the prospect. 12. Agents will conduct a Suitability Assessment with all clients to determine what Humana plan, if any, is appropriate for the client. Agents will sell or replace a plan only when it is clearly in the policyholder s best interest and without regard for the agent s compensation. 13. Should the client express interest in a plan other than what was agreed to in advance of the inhome appointment, the agent should secure a Scope of Appointment prior to the presentation of any other plans, regardless of carrier. If the agent initiates the discussion, the subsequent appointment should be no sooner than 48 hours later unless not feasible. This should be the exception and the reason must be recorded on the Scope of Appointment form. 14. Only licensed agents who present the benefits of the plan and confirm their intent to enroll may sign the application as the selling agent of record. 15. Agents are responsible for all applicable insurance licenses required to sell MA, PDP, or Medigap plans in all states in which they market. Agents must have a valid resident or non-resident license issued from the state where the Medicare beneficiary permanently resides in order to market or sell an MA, PDP, and/or Medigap plan. 16. Agents will use only Humana and CMS or State approved materials, unless generic (does not include plan benefits or plan name), to market to prospective enrollees. In addition, any/all communications that include plan benefit or plan name sent to current members, e.g. letters, flyers, mailers, etc, must also be approved by Humana and CMS or the state DOI prior to their use. Agents will not modify or alter approved materials for their use in member communications or the marketing and sale of MA, PDP, and/or Medigap plans. 9

Section II Code of Ethics (continued) 17. Agents may not send e-mails to Medicare beneficiaries unless the person has agreed in advance to receive emails and have provided his/her email address personally. Agents can not rent or acquire an email address through any type of directory, nor can the agent disclose the beneficiary s email address to any other sources or entities without prior approval to do so. 18. Agents may not maintain social network accounts (i.e. Facebook, Twitter) for the purpose of generating MA/PDP sales leads generation. 19. Agents may not ask Medicare beneficiaries for referrals during a Medicare Advantage marketing event or personal appointment. 20. Agents may not accept any compensation, e.g. commissions, cash, prizes, gifts, etc for the sale or referral of Humana Medicare business outside of what is specifically outlined in their Humana compensation plan. Agents may not offer or accept gifts from providers and/or territorial contacts; arrange to share or split their MA/PDP/Medigap incentives; accept additional financial incentives; or otherwise allow themselves to be influenced or coerced in any way in the conduct of their business. 21. Agents are prohibited from charging beneficiaries additional marketing fees for enrollment beyond the base premium. 22. Agents will not involve themselves in providing legal advice concerning the need for Healthcare Power-of-attorney, facilitating the execution of Healthcare Power-of-attorney documentation, disenrollment from another plan, medical referrals (as applicable) or any other activity that could be viewed as unethically influencing an enrollment. 23. Agents may neither give nor offer a gift or payment of any kind to a prospective MA, PDP and/or Medigap member as an inducement to enroll in a Humana plan. Agents may not offer any form of incentive, e.g. cash, gifts, etc, to a member as a reward for referrals provided by the member. An offer of a rebate in any form is strictly prohibited. CMS permits the use of gifts of a nominal value, defined as having a value of $15 retail or less and that can not be readily converted to cash. Agents may not provide meals or snacks that can be bundled to make a meal, of any value during promotional or sales activities. 24. Agents are prohibited from providing any form of cash or payment to a member to assist the member in the payment of their plan premium, copayments, pharmacy copayments, plan coinsurance, etc. 25. Agents will assure, to the best of their ability, that the prospective enrollee is of sound mind and capable of thoroughly understanding the plan. If, at any time, they doubt the enrollee s mental ability to comprehend, they will discontinue the enrollment until such time as they can meet with someone with appropriate legal authority to enroll the Medicare eligible prospect. 26. Agents may indicate that the Humana MA, PDP, and/or Medigap plans meet criteria specified by government agencies. They will never imply that their visit is in any way connected with the government, endorsed by the government or approved by a particular government agency or official, or portray themselves as a representative of Medicare or any other government agency 10

Section II Code of Ethics (continued) 27. Agents understand that the Humana operates its Medicare programs and offers its MA, PDP, and/or Medigap plans and services to all enrollees and applicants for enrollment without regard to race, color, religion or national origin in compliance with Title VI of the Civil Rights of 1964. In addition, all agents must observe the company s policy of non-discrimination on the basis of race, creed, color, sex, age, national origin and health status, except as provided by the Federal Register and/or CMS guidelines. 28. In the event an allegation of misconduct is lodged against an agent, the Agent will provide a detailed written response to the complaint within 5 business days of notification of the complaint. Additionally, the agent will not contact beneficiaries that have lodged a Section A or Agent Misconduct complaint without prior approval from the MarketPOINT Sales Administration and Compliance s Department. 29. It is Humana s policy that no delegated sales agent is to engage in cold-calling for the direct or indirect purposes of enrollment in a Humana Medicare Advantage (MA) and/or Prescription Drug Plan (PDP). Agents may not engage in unsolicited contact to prospective members except in very limited situations including: Initiating a phone call to confirm an appointment that was already agreed upon by the prospective member. Initiating a phone call to a prospective member who had given prior express permission for the plan or sales agent to contact them. Permission to contact is given on a limited, eventspecific, basis. Agents may contact members that they enrolled to discuss plan issues and/or market other health-related plan options. Medicare Supplement members may be contacted. Should the beneficiary indicate interest in discussing a MA or PDP product, that product may be discussed provided the discussion is recorded and a Scope of Appointment form is completed. However the Medicare Supplement call may not be used under the guise of selling a non-ma or non-pdp product. 30. Agents are required to make every effort to confirm that the prospect, client or Humana member has not previously indicated that they do not want to be contacted for the purpose of marketing/sales 31. Agents must not accept paper applications prior to the start of the Annual Enrollment Period. 32. Agents will not permit the telephonic signature of the enrollee s name, with or without the enrollee s permission, on the enrollment application by any person other than the enrollee. Agents will not knowingly accept a telephonic signature other than the enrollee s on an application for any product, except in the case of an authorized Healthcare POA. Agents are responsible to ensure that all information on an application is complete, accurate, and will not alter, remove, replace or misrepresent any information obtained from the prospect. 11

Section III Commission Schedules A. Commission: See Attached Commission Schedule(s) which are made part of the GPA Contract Medicare Amendment and Medicare Advantage Plans and Prescription Drug Plan Sales and Marketing Agreement. ADDITIONAL PROVISIONS The provisions below apply to the GPA Medicare Advantage Referral Program Commission Schedule(s) and the GPA Medicare Advantage and Prescription Drug Plan Commissions Schedule(s) in which the GPA is participating. B. Payment of Compensation Commissions can only be paid to GPAs that are actively appointed to sell in the State (if required) and who have completed annual training and testing per the Company policies and procedures with a passing score of eighty-five (85) percent. Commissions will be paid on a weekly basis (calculations on Wednesdays with payments by Friday) based on the enrollments entered into the system that have passed compliance edits for licensing, appointment and certification and that are not in pending status. Charge backs will occur for any enrollment that is NOT confirmed by CMS as an eligible member. Non MECA GPAs may participate in both the Medicare Advantage Agent Referral Program and the GPA Medicare Advantage or Prescription Drug Plan Delegated Sales and Marketing Program; however, the GPA will not be paid both a referral fee and a Delegated Sales commission for both the referral and enrollment on the same individual. In such cases, only the Delegated Sales commission and any applicable Delegated Sales renewals and/or overrides will be paid. Members enrolled through the GPA who voluntarily or involuntarily disenroll within the first eleven (11) effective months may be subject to a charge-back of commissions based on the commission schedule. GPAs will not be paid for any sales MA or PDP enrollment when the GPA is not certified by Humana to sell the specific Medicare plan product or when the agent is not appropriately licensed or appointed in the state in which the enrolled member resides. The GPA agrees that unless the GPA disputes a commission amount for a respective sale, policy or enrollment or the failure by the Company to pay a commission for a respective sale, policy or enrollment in writing within eighteen (18) months from the date the commission is earned, the GPA agrees that the commission determination or commission payment amount made by the Company for the respective sale, policy or enrollment is correct and that no claim, demand, legal action or litigation against the Company may be brought by GPA regarding a respective sale, policy or enrollment unless made within twelve (12) months from the date the GPA disputes the commission. For purposes of this Section the phrase from the date the commission is earned means the date upon which (i) the commission is initially earned, (ii) the commission is recalculated as a result of changes in the risk affecting the premium charged, policy termination and/or policy cancellation and (iii) the commission is recalculated by agreement of the parties hereto. C. Modifications or Termination All monetary compensation, including commissions, renewal commissions, and overrides, may be modified, increased, reduced, or discontinued by written notice from the Company and shall take effect at the time specified in the notice, but in no event prior to 30 days from the date such notice is mailed to the GPA s last known address as reflected in the Company s records. 12

AGENT ATTACHED COMMISSION SCHEDULE GROUP PRODUCING AGENT (GPA) MEDICARE ADVANTAGE PLANS AND PRESCRIPTION DRUG PLANS COMMISSION SCHEDULE THIS COMMISSION SCHEDULE IS PART OF THE GPA MEDICARE ADVANTAGE PLANS AND PRESCRIPTION DRUG PLAN SALES AND MARKETING AGREEMENT This Commission Schedule supersedes any previous Commission Schedules regarding Medicare Advantage Plans and will apply to new Medicare Advantage Plan enrollments with effective dates of coverage on or after January 1, 2013. Per CMS guideline, Specific Guidance on Compensation Strategy Chapter 3, Section 120 Medicare Managed Care Manual, commissions can only be paid to GPAs that are actively licensed and appointed to sell in the State (if required) and who have completed annual training and testing per the Company policies and procedures with a passing score of eighty-five (85) percent. No new or renewal commission can be paid unless the agent is currently certified. GPA Commissions will be paid to the GPA for all commissionable enrollments on an as submitted basis for new and effective date basis for renewals, according to the then in effect commission payment system cycle as determined by Humana. Submitted is defined as being entered and accepted into the Humana enrollment system. In order for the Agent to receive the commission for a particular Qualified Enrollment, the writing agent who provides the basis for the commission must meet all applicable Company requirements to receive commission from the Company. The commission cycle calculations are run each week on Wednesday with commission payments transmitted electronically or mailed by Friday Charge-backs of previously paid commissions will result for enrollments that are not approved by CMS as a Qualified Enrollment. Members enrolled through the GPA who voluntarily or involuntarily disenroll within the first 3 effective months and have no continuous coverage with a Company plan are considered shortterm disenrollments and will result in charge-backs of all previously paid commissions (for example, effective 1/1 and disenroll effective on or before 4/1). Charge-backs will be for the amount of the commissions paid to the GPA and will be charged against future compensation and any other monetary compensation or commission that would otherwise be payable to the GPA. Humana will recover a pro-rated amount for the months remaining in the Enrollment Year, instead of the full Commission, if the enrollee disenrolls during months 1 through 3 of the Enrollment Year for any of the reasons listed in the table below: 13

Category Special Election Period ( SEP ) Exceptional Circumstances Change in Status Auto or Facilitated Enrollment Involuntary Disenrollment Reason Qualifies under the SEP for disenrollment from Medicare Part D due to other creditable coverage (as defined under Applicable Law). Qualifies under the SEP for disenrollment from Medicare Part D due to institutionalization (as defined under Applicable Law). Enrollee gains or drops employer- or union- sponsored coverage. Enrollee is disenrolled because of a CMS sanction against Humana. Enrollee is disenrolled during the Medigap trial period. Enrollee is disenrolled in order to coordinate with Part D enrollment periods. Enrollee is disenrolled in order to coordinate with a state pharmaceutical assistance plan. Enrollee becomes dually eligible for both Medicare and Medicaid. Enrollee becomes eligible to enroll in another plan based on special needs. Enrollee becomes eligible for the Medicare Part D low income subsidy (as defined under Applicable Law) Enrollee qualifies to enroll in another plan based on a chronic condition. Enrollee moves into or out of an institution (as defined under Applicable Law). Enrollee disenrolls due to auto or facilitated enrollment (as defined under Applicable Law). Enrollee dies. Enrollee moves out of the service area of the Product. Enrollee is disenrolled due to non-payment of premiums. Enrollee loses entitlement to Medicare. Enrollee disenrolls due to retroactive notice of Medicare entitlement. Enrollee disenrolls due to a contract violation. Enrollee disenrolls due to non-renewal or termination of a Product. Members enrolled through the GPA who voluntarily or involuntarily disenroll between effective months 4 and 12 of the enrollment period and have no continuous coverage with a Company plan are considered long-term disenrollments and will result in a pro-rated charge-back of previously paid commissions equal to those months the member was not enrolled on the plan (e.g. effective 1/1 and disenroll effective 5/31 = 7 months chargeback). Charge-backs will be for the amount of the commissions paid to the Agent and will be charged against future compensation and any other monetary compensation or commission. The pro-rated chargeback rule applies to all years of plan membership by the member; and excludes beneficiaries disenrolled due to death. Commissions will discontinue when the Agent of Record (AOR) on the MA or PDP Qualified Enrollment is no longer eligible to receive commissions for that Qualified Enrollment. In the event of a not for cause AOR termination renewal commissions will continue to be paid based on the renewal commission schedule as long as the associated member is active. In the event of a for cause termination, commissions will discontinue. The GPA agrees that unless the GPA disputes a commission amount for a respective sale, policy or enrollment or the failure by the Company to pay a commission for a respective sale, policy or enrollment in writing within eighteen (18) months from the date the commission is earned, the GPA agrees that the commission determination or commission payment amount made by the Company for the respective sale, policy or enrollment is correct and that no claim, demand, legal action or litigation against the Company may be brought by GPA regarding a respective sale, policy or enrollment unless made within twelve (12) months from the date the GPA disputes the commission. For purposes of this Section the phrase from the date the commission is earned means the date upon which (i) the commission is initially earned, (ii) the commission is recalculated as a result of changes in the risk affecting the premium charged, policy termination and/or policy cancellation and (iii) the commission is recalculated by agreement of the parties hereto. 14

Modifications or Termination: GPA Commissions may be modified, increased, reduced, or discontinued by written notice from the Company and shall take effect at the time specified in the notice, but in no event prior to 30 days from the date such notice is mailed to the Agency s last known address as reflected in the Company s records. DELEGATED AGENT COMMISSION SCHEDULE Plan Type - Medicare Advantage First Year - Initial Sale Subsequent Years (2-6) New Medicare Advantage State $ Amount State $ Amount Puerto Rico $280 paid first month Puerto Rico $11.67 pmpm ($140 annually) California $517 paid first month California $21.58 pmpm ($259 annually) AK/AZ/CT/Hi $413 paid first month AK/AZ/CT/Hi $17.25 pmpm( $207 annually) NJ/NV/PA/TX NJ/NV/PA/TX All Other States $365 paid first month All Other States $15.25 pmpm ($183 annually) Plan Type - MA Product Change First Year - Replacement Subsequent Years (2-5) MA Product Changes (HMO to PPO, PFFS to PPO, RPPO to LPPO, from other Carriers, etc.) State $ Amount State $ Amount Puerto Rico $140 paid first month Puerto Rico $11.67 pmpm ($140 annually California $259 paid first month California $21.58 pmpm ($259 annually AK/AZ/CT/Hi $207 paid first month AK/AZ/CT/Hi $17.25 pmpm( $207 annually) NJ/NV/PA/TX NJ/NV/PA/TX All Other States $183 paid first month All Other States $15.25 pmpm ($183 annually) Plan Type - Prescription Drug First Year - Initial Sale Subsequent Years (2-6) State $ Amount State $ Amount All PDP Plans All States $56 paid first month All States $28 paid first month Plan Type PDP Product Change PDP Product Change (from other Carrier) Plan Type - MA & PDP Plan Changes (same Contract number, PFFS A to PFFS B, HMO to HMO SNP, PDP Standard to PDP Enhanced) First Year - Replacement Subsequent Years (2-5) State $ Amount State $ Amount All States $28 paid first month All States $28 paid first month Original AOR remains - renewal commissions paid based on originating plan's effective date pmpm = per member per month. Note on Initial Sales Commissions: All initial sales will be paid at the renewal rate (half of initial rate) with an additional commission payment paid upon CMS validation. The sum of the two payments will equal the full initial sales commission rate. Validation will be provided by CMS reporting. For example: an initial MA sale in Florida would be commissioned at $183 with an additional payment of $183 if validated by the CMS reports. 15

AGENT ATTACHED COMMISSION SCHEDULE HUMANA MEDICARE SUPPLEMENT COMMISSION SCHEDULE THIS COMMISSION SCHEDULE IS PART OF THE GPA CONTRACT AND GPA MEDICARE ADVANTAGE PLANS AND PRESCRIPTION DRUG PLAN SALES AND MARKETING AGREEMENT This Agent Commission Schedule supersedes any previously executed schedule and will apply to new business with beginning effective dates of coverage on or after January 1, 2013. Humana Medicare Supplement Plan commissions will be paid based on manual premium, which is the initial premium in effect on the application date of the issued policy. Commissions are not paid on any premium increases during the life of the policy. In the following states of CO, IL, IN, KS, ME, MO, PA, WI, Humana DOES pay commissions to agents for policies sold to applicants who are under age 65 or over age 80 at the time of the sale. In the following states of AZ, AR, CA, CT, FL, ID, MA, MI, MN, NV, NJ, NY, OR, PR, RI, VT, WA, Humana DOES NOT pay commissions to agents for policies sold to applicants who are under age 65 or over age 80 at the time of the sale. NOTE: IF a member turns 81 during the life of the commissions, agents will still receive commissions accordingly. In all states EXCLUDING the states above, Humana DOES NOT pay commissions to agents for policies sold to applicants who are under age 65 at the time of the sale. Humana does pay commissions for policies sold to applicants age 80+ as of the effective date. Commissions calculated as a percentage of initial premium are based on paid premium only. Humana reserves the right to exclude any case from eligibility for commission, bonus or recognition programs at their sole discretion. Commission is not payable for policies written for beneficiaries under age 65 or over age 80 at the time of the sales except in the following states where commissions are paid regardless of policyholder age: Colorado, Illinois, Indiana, Kansas, Maine, Missouri, Pennsylvania, and Wisconsin. NOTE: If a member turns 81 during the life of the commissions will still be paid accordingly. Commissions will be paid for all commissionable enrollments on a submitted basis for new and effective-date basis for renewals, according to the then in-effect commission payment system cycle as determined by Humana. Submitted is defined as being entered and accepted into the Humana enrollment system. In order for Company to receive the commission for a particular Qualified Enrollment, the writing agent who provides the basis for the commission must meet all applicable Humana requirements to receive commission from the Humana. The commission cycle calculations are run each week on Wednesday with commission payments transmitted electronically or mailed by Friday 16

Commissions will discontinue when the Agent of Record (AOR) on the Med Supp Qualified Enrollment is no longer eligible to receive commissions for that Qualified Enrollment unless Company assigns another licensed, appointed and Humana-certified agent as AOR. In the event of a not for cause AOR termination renewal commissions will continue to be paid based on the renewal commission schedule as long as the associated member is active. In the event of a for cause termination, commissions will discontinue unless Company assigns another licensed, appointed and Humana-certified agent as AOR. In the event any policy on which the GPA is entitled to commissions lapses because premium is not paid and the policy is replaced or reinstated, any commission on the new or reinstated policy is payable only at the company s discretion. To receive commissions, the writing agent name that appears on the insurance application must report to the GPA hierarchy at the time of the sale. The respective commissions shall be subject to decision and settlement by the company. The company s decision is final and binding upon the parties involved. If it is necessary to rescind coverage for any policy, the producer shall promptly refund to the company any commissions received by him/her on account of the policy. If coverage is surrendered, rescinded or cancelled and premiums are refunded or waived, the producer shall, in all cases, lose all rights to corresponding commissions and shall repay commissions to the company on demand. The GPA shall pay over promptly to the company all premiums received or collected on behalf of the company, and shall not deduct or retain commissions, which may be payable hereafter. No commissions will be payable hereafter with respect to premiums refunded for any reason. There shall be no additional compensation or reimbursement to the GPA for expenses incurred in performing services hereafter. First Year Commissions means monthly commissions payable during the initial twelve-month term of coverage. Renewal Commissions means monthly commissions payable during the term of coverage other than the initial twelve-month term. Coverage converted from one Humana subsidiary to another, or from one product to another, is not considered new business for commission purposes. Commission schedules are not affected by off-cycle renewals or a coverage change to a different product within a product line if there is no lapse in coverage. The initial monthly premium and effective date will control Commission Schedules. Humana and its subsidiaries are the final arbiter of any issues related to commission programs. Humana and its subsidiaries reserve the right to modify or terminate any part of any commission, bonus or recognition program for all cases regardless of the effective date of coverage at any time without notice. The GPA agrees that unless the GPA disputes a commission amount for a respective sale, policy or enrollment or the failure by the Company to pay a commission for a respective sale, policy or enrollment in writing within eighteen (18) months from the date the commission is earned, the GPA agrees that the commission determination or commission payment amount made by the Company for the respective sale, policy or enrollment is correct and that no claim, demand, legal action or litigation against the Company may be brought by GPA regarding a respective sale, policy or enrollment unless made within twelve (12) months from the date the GPA disputes the commission. For purposes of this Section the phrase from the date the commission is earned means the date upon which (i) the commission is initially earned, (ii) the commission is recalculated as a result of changes in the risk affecting the premium charged, policy termination and/or policy cancellation and (iii) the commission is recalculated by agreement of the parties hereto. 17

AGENT ATTACHED COMMISSION SCHEDULE NON-MEDICARE OTHER PRODUCTS COMMISSION SCHEDULE THIS COMMISSION SCHEDULE IS PART OF THE GPA CONTRACT AND GPA MEDICARE ADVANTAGE PLANS AND PRESCRIPTION DRUG PLAN SALES AND MARKETING AGREEMENT This Commission Schedule supersedes any previous Commission Schedules regarding non-medicare related products, including Dental and Vision products underwritten by CompBenefits Insurance Company and all Humana Financial Protection products underwritten by Kanawha Insurance Company, with effective dates of coverage on or after January 1, 2013. So long as the GPA or an Assigned Agent is recognized as the Agent of Record on a given Account and as full compensation for all services rendered hereunder and for all expenses incurred by GPA in the performance of said services, the Company agrees to pay to GPA commissions ( Commissions ) on Net Contributions and on Enrollment Fees received and accepted by the Company on Certificates issued and while related to a given Account on applications directly obtained by the GPA or Assigned Agent under the authority of the GPA Contract; such Commissions being at the rates by product sold as set forth in this Agent Commission Schedule, or as otherwise agreed, in writing, by Company. It is acknowledged and agreed that notwithstanding anything contained in this Contract to the contrary, no Commissions shall be due and payable on any given individual subscriber where said individual subscriber becomes no longer affiliated with the Account in which he/she was originally associated. The commission cycle calculations are run each week on Wednesday with commission payments transmitted electronically or mailed by Friday As compensation for GPA s services hereunder for solicitation and subsequent enrollment of Individual Subscribers (with no group affiliation), Company shall pay GPA a percentage of the Enrollment Fee ( Finders Fee ) for each individual enrollment application that is delivered by GPA or Assigned Agent to Company, such percentage being set forth in this Commission Schedule. Company shall have the right to reject enrollment cards, in good faith, which do not meet proper standards set forth to initiate such plans. Any Commissions becoming due to the GPA or assigns may be accumulated and paid by the Company at such time as the Commissions so accumulated total at least Fifteen Dollars ($15) per month. Company reserves the right to change this minimum monthly amount from time to time without notice. In the event the Company shall either fail to collect or return all or a portion of the Contributions or Enrollment Fees on a Certificate, or shall cancel a Certificate for any reason whatsoever, the GPA shall promptly repay to the Company the amount of Commissions or Enrollment Fees attributable thereto. In the event the GPA fails to promptly repay to Company said Commissions or Enrollment 19