Cigna: Additional Guidance on TPMO Reporting Requirements

TPMO Reporting Requirements - Reminders and FAQs

In support of CMS Final Rule requirements which were released earlier in the year, Cigna would like to remind you of the Third-Party Marketing Organization (TPMO) reporting requirements related to subcontracted relationships, issues of non-compliance, and employee disciplinary actions. 

As Cigna communicated previously, you are responsible for reporting this information to Cigna according to CMS guidelines. The action steps below and Frequently Asked Questions (FAQs) will assist you in meeting these requirements. 

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Requirement 1: Disclose any subcontracted relationships to Cigna

What? All sales agencies contracted with Cigna are required to send a file of all their TPMO relationships (who are compensated to perform lead generation, marketing, sales, and enrollment-related functions).

How? A template has been created that you will be required to complete and send to the CARL team (CARL@cigna.com). On an ongoing basis, you must notify Cigna of any changes in subcontracted relationships. Log in to Producers' University, and visit the Resource Center > Compliance > Sales Guidance and Policies > Third Party Marketing Organizations (TPMO) to access the template.

When? Disclosure to Cigna is only required as changes occur.

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Requirement 2: Disclose compliance violations to Cigna

What? All sales agencies contracted with Cigna must report the following: Any instances of non-compliance associated with a beneficiary interaction and/or any violations of requirements that apply to Cigna and any staff disciplinary actions taken as a result.

How? A templatehas been created that you will be required to complete and send to the CARLteam (CARL@cigna.com). Log into Producers' University, and visit the Resource Center > Compliance> Sales Guidance and Policies > Third Party Marketing Organizations(TPMO) to access the template.

When? The completed template must be sent to the CARL team by the last day of each month. However, you are not required to report N/A or None if there are no issues of non-compliance to report.

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Login to Producers' University to view the following FAQ documents. Please note: You must be logged in to access the links.

Cigna Final Rule TPMO Requirements FAQ

CMS 2023 Medicare Advantage Marketing Policies FAQ