Registration and training before Open Enrollment
Priya is a licensed agent in two FFM states. On October 24, she completed CMS Enterprise Portal identity proofing and began the current plan-year FFM registration training. She finished modules 1–3, left module 4 incomplete, and has not attempted the final assessment. She has 40 purchased leads and wants to begin appointments on November 1, the first day of Open Enrollment. Her unlicensed assistant, Dev, answers the phone and wants to email plan comparisons and premium estimates to leads. Priya’s business partner, Marco, completed FFM registration training last plan year and has a certificate dated February 2024 but has not started this year’s training. Priya asks whether she can enroll consumers next week, whether Dev can send the emails, and whether Marco can conduct appointments while she finishes training. She also plans to call every lead twice, including numbers on the Do Not Call Registry.
1. Can Priya begin Marketplace enrollment appointments on November 1? Identify each registration and training condition and explain the consequence of starting early.
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No. Registration is plan-year specific, so Priya must complete the required training for the current plan year, pass the final assessment, and sign or attest to the applicable Marketplace agreements before performing agent functions. Her incomplete module 4 means she has not earned a current completion certificate, even though she completed identity proofing and three modules.
Starting appointments on November 1 would be unauthorized Marketplace activity. The practical consequences include possible registration suspension or termination, compliance action against her and her agency, and risk to the consumers’ enrollments. She may prepare operationally-reviewing plan data, organizing leads, and confirming appointments-but she must not discuss eligibility, quote premiums, recommend plans, or submit applications until registration is complete. She should also confirm that her state licensure and any required appointments are active in each state where she intends to enroll consumers.
2. What tasks may Dev perform before completing FFM registration, and what tasks are off-limits?
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Dev may perform clerical and administrative work that does not involve Marketplace education, eligibility, plan selection, or enrollment. Examples include answering the phone, scheduling appointments, confirming contact information, and routing messages. Dev should be clearly supervised and must not use Marketplace branding in a way that implies he is a registered agent.
Emails containing plan comparisons and premium estimates are not clerical. They require discussion of plan benefits and costs, which is an agent function. If Dev sends those emails, he is effectively providing Marketplace information and must be properly registered and trained for the current plan year, and licensed where required. Priya should either keep Dev in an administrative role or complete the required registration steps before assigning him consumer-facing plan work.
3. Marco wants to conduct appointments using last year’s certificate. What should Priya tell him, and how should the lead-call plan be adjusted?
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Priya should tell Marco that a prior-year certificate does not satisfy the current plan-year registration requirement. FFM registration and training must be completed annually, so Marco must complete the current training, pass the current assessment, and sign or attest to the required agreements before conducting appointments. Until then, he cannot enroll consumers or discuss Marketplace eligibility and benefits.
For the lead calls, a purchased list does not prove that consumers consented to calls. Priya should verify whether valid consent exists, scrub the list against the Do Not Call Registry, and avoid calling numbers without consent. Calling every lead twice regardless of consent creates compliance risk and may also violate telemarketing rules. Priya should document consent, train staff on call scripts, and postpone consumer contact until registration and consent issues are resolved.