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who typically sell multiple plans or change
agencies have become increasingly resistant
to “another compliance training program.”
Absent guidance from CMS, agents may be
required to take several compliance-mandated
training courses that have not always been
inspiring.
The final complicating factors are the market
and the need for all companies to be efficient
and cost-effective in their operations. Competition
among health plans to retain current
members and attract new members will only
increase as the pool of unaffiliated Medicare
beneficiaries decreases. In order for health
plans to comply with regulations and budgets,
training has to produce demonstrable
cost, compliance, and learning results beyond
merely achieving regulatory requirements.
The MAPD and PDP compliance training
program at Health Care Services Corporation
(HCSC) is achieving all three objectives.
n Comply with CMS requirements for
broker and agent training, ensuring that
all agents were trained and that all broker
agencies agreed to HCSC’s business
contract;
n Ensure consistent training throughout
the HCSC organization, including both
internal and external audiences;
n Create a database of agents authorized to
sell our products. (Among the states we
serve, only Texas does not require such a
database.) We needed to track not just the
employees of each agency, but the subcontractors
who were selling our policies.
n Optimize compliance training through its
use as a tool to develop and support agent
loyalty;
n Reduce training costs, which had previously
relied on in-person training that
required virtually non-stop travel by
HCSC employees throughout our fourstate
service region.
they can be automatically authenticated and
approved for training.
The capabilities of the solution were familiar
to HCSC because it was already being used
for other in-house compliance training. The
solution uses the application service provider
(ASP) or hosted model, which allows data
to be stored securely outside our firewall and
virtually eliminated the capital, administrative,
and maintenance costs associated with
purchasing new infrastructure. This was key,
because we could not allow non-employees,
such as agents, brokers, or other downstream
entities to enter our firewall to take the training.
Finally, the solution creates the documentation
required by CMS, including e-signature
validation that all learners have received the
training courses and have been tested for
comprehension of each course’s subject matter.
The documentation of all training activities is
available in audit-ready format.
HCSC business and compliance goals
HCSC serves members in four states through
our Blue Cross/Blue Shield divisions in Illinois,
Texas, New Mexico and Oklahoma. Our
MAPD and PDP plans are offered through
our subsidiary HCSC Insurance Company
(HISC).
In September 2007, we launched a training
program that was offered through November
14. In compliance with CMS’ rules, we
stopped the training on November 14, the
day prior to the beginning of the enrollment
period for 2008 MAPD and PDP plans. Our
training program was developed to achieve
well-defined goals that supported the HCSC
commitment to “best in class” service to our
members. Our objectives included:
n Provide our members with unequalled
service by ensuring that all agents are
equipped to accurately explain our plan to
current or potential members;
Achieving our training objectives
The MAPD and PDP compliance training
program at HCSC reflects an enterprise-wide,
long-term approach. Because of the number
and diverse locations of agents, we chose an
online training system that supported remote
workers, met CMS’ documentation needs, and
provided the critical management capabilities
for an efficient, cost-effective program.
The program was built on the decision to
create a single program that would be used by
all brokerage agencies, regardless of their state
locations. We developed a program based
on an enterprise-wide, compliance-specific,
learning management system and MAPD and
PDP specific-training courses (herein referred
to as the solution). Agents with authorization
to sell our Medicare-regulated prescription
drug plans are required to self-register for the
training. All 21,000 HCSC-authorized agents
have been pre-loaded into the system, so that
Before receiving any training material, each
broker is required to sign a contract (i.e.,
licensing agreement) with HCSC’s specific
conditions for performance. Only after signing
the agreement does the agent then receive
an online “package” containing a producer
training course, three forms, and a survey
that must be completed as the final element
of the training program. The producer
training course is broken into seven chapters:
Overview, enrollment, plans, formulary,
prescription policy, marketing guidelines,
and fraud, waste, and abuse. The three forms
contained in the agent’s training package are
the company’s Medicare and Government
Contracts Compliance Program, a Compliance
Checklist, and the HISC Amendment,
which includes the commission structure.
Each chapter of the seven courses concludes
with a learning activity and challenge. An 80%
Continued on page 69
Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
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October 2008