Effective January 1, 2019, CMS no longer requires Plan Sponsors to ensure that their First Tier, Downstream, and Related Entities (FDRs) complete the CMS-published training modules. However, FDRs are still required to comply with all statutes, regulations and CMS guidelines. As such, it is advisable that our downline agencies continue to educate and document efforts to ensure your non-agent employees (non-licensed staff or licensed staff who are not appointed by any Medicare Advantage insurance company), management, temporary workers or subcontractors are aware of these guidelines.
You may develop your own training material or utilize carriers’ Code of Conduct or training material. You may also utilize the Ritter Code of Conduct and training material published on our website. Such training must be provided within 90 days of hiring and annually after.
Here at Ritter, we strive to promote excellence and quality in the products and services we provide to our business partners, agents, and customers. As a field marketing organization (FMO) in the health insurance industry, we have contracts as a First Tier Entity with insurers that offer Medicare Advantage and prescription drug plans. As such, we are aware of the importance of complying with all applicable laws, regulations, and Center for Medicare & Medicaid Services guidelines.
We expect our agents to abide by the best practices of marketing Medicare including all governmental regulations. Our agent handbook provides agents with foundational knowledge of Medicare sales practices.
Our compliance program seeks to promote legal and ethical business conduct and prevent, detect, and resolve non-compliance and illegal conduct. It meets the Seven Elements of an Effective Compliance Program put forth by the Office of Inspector General of the Department of Health and Human Services.
Ritter Code of Business Conduct
Our goal has never solely been to comply with the laws, but also to follow the highest principles of integrity and honesty. The Ritter Code of Business Conduct puts our core values into practical terms that provide ethical and compliance guidelines and expectations to help guide our day-to-day business activities.
Ritter strives to conduct business with individuals or entities that share our view toward compliance and ethics. Therefore, we expect our agents to respect and subscribe to the Ritter Code of Business Conduct when conducting business with or on behalf of our company.
All Ritter agents are responsible for following the Ritter Agent Handbook, the Ritter Code of Conduct, the applicable carrier’s code of conduct, as well as carrier-specific policies and procedures. For your convenience, we have put links to the codes of conduct for the insurance carriers we represent here in one place.
To view a specific carrier’s code of conduct, please click on the appropriate link below.
|Aetna||EmblemHealth||Independence Blue Cross|
|Affinity Health Plan||Excellus||SilverScript|
|Asuris Northwest Health||HCSC||Vibra|
|Avalon Insurance Company||Health Partners Plans|
|CareMore||Humana Pt. 1|
|Clover Health||Humana Pt. 2|
As a First Tier Entity, Ritter must review the Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals and Entities and the General Services Administration (GSA) Excluded Parties List System to ensure its employees, management, temporary workers, or subcontractors, if applicable, are not listed on these exclusion lists. These databases must be checked prior to hiring the aforementioned types of personnel and at least once a month so long as they remain with Ritter.
Similarly, Ritter’s downline agencies must review these databases to ensure their non-licensed personnel are not listed on these exclusion lists if they utilize these individuals to support their Medicare business. These exclusion lists must be checked prior to these individuals being hired and monthly thereafter.