Bulletin No. B-4.87 Prohibition on Differing Commission Structures for the Sale of Health Benefit Plans I.
Background and Purpose
The purpose of this bulletin is to inform carriers that the Division of Insurance (Division) applies Colorado’s Fair Marketing Standards, as specified in § 10-16-108.5, C.R.S., to any commission structure that appears to discourage producers from actively marketing certain plans or plans from certain carriers. Bulletins are the Division’s interpretations of existing insurance law or general statements of Division policy. Bulletins themselves establish neither binding norms nor a final determination of issues or rights. II.
Applicability and Scope
This bulletin is intended for all carriers who sell individual and/or small group health benefit plans in the State of Colorado. III.
Division Position
It has come to the attention of the Division that carriers are paying differing commissions depending upon the metal tier of the plan sold; not paying commission on plans purchased outside of open enrollment due to a qualifying special enrollment period (SEP); and/or not paying commissions on certain plans offered in the State of Colorado (collectively referred to herein as “differing commission structures”). These types of differing commission structures appear to be an attempt, at a minimum, to avoid or reduce carrier risk by discouraging the sale of plans where a carrier is responsible for a greater portion of the health care costs incurred; an attempt to avoid paying commission when a consumer is granted an SEP due to a triggering event; an attempt by a carrier to discourage the sale of its plans, either on or off of the Exchange, within Colorado without actively discontinuing plans or exiting the market; and/or these differing commission structures will have the effect of directly or indirectly incentivizing the sale of those plans for which the carrier will pay commissions and dis-incentivizing the sale of those plans for which no commission is paid. Regardless of rationale for the differing commission structures, at a minimum, paying differing commission structures for plans has the effect of running counter to the requirement for the “fair marketing and broad availability of health benefit plans” found at § 10-16108.5(8), C.R.S.
Furthermore, any carrier that employs these types of differing commission structures will be in violation of various provisions of Article 16 as well as the unfair competition and deceptive practices set forth at § 10-3-1104, C.R.S. Any carrier that employs these types of differing commission structures would subject itself to enforcement actions to remedy those violations, including but not limited to, licensure actions, enforcement actions seeking civil penalties, and enforcement actions for the refund of unearned premium plus any allowable penalties for the collection of unearned premium. IV.
Additional Division Resources
A.
For More Information Colorado Division of Insurance Life and Health Consumer Services Section 1560 Broadway, Suite 850 Denver, CO 80202 Tel. 303-894-7499 Toll Free: 1-800-930-3745 Internet: http://www.dora.colorado.gov//insurance
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