1. Agent Guidelines
Compliance Code #HMIAT003003

2. Agenda Agent Guidelines Ethics Philosophy
Financial/ Contractual/Other Responsibilities
Integrity
Agency Standards
Agency Communication
Complaint Handling
Federal Compliance Requirements
This training outlines the fundamental requirements for how HealthMarkets Agents are to conduct their business and identifies resources that may assist Agents in evaluating and answering difficult questions.

3. HealthMarkets
HealthMarkets Insurance Agency (“HealthMarkets”) serves as a multi-carrier distribution channel offering
There are fundamental requirements for agent conduct
Each agent is accountable for their own actions
Health
Life & Annuity
Medicare
Long-Term
Care
HealthMarkets Insurance Agency (HMIA) is a multi-carrier distribution channel. We represent Insurance Companies and other entities offering a wide range of health, life, Medicare, long-term care insurance, and annuity products. As such, there are requirements for agent conduct both by HealthMarkets and the carriers we work with. Each agent is accountable for their own actions and will be held to the standards for agent conduct.

4. Agent Guidelines Read and understand HMIA’s Agent Guidelines
Located on the resource center under My Profile  Agency Standards Home  Agency Standards Documents  HealthMarkets Agent Guidelines
Questions should be directed to
Territory Vice President
Open communication is encouraged
Ethics Hotline
Good judgment and common sense
It is necessary for each agent to read and understand HMIA’s Agent Guidelines. The Agent Guidelines can be found on the Resource Center under My Profile > Agency Standards Home > Agency Standard Documents > HMIA Agent Guidelines.
As an agent with HealthMarkets, you agree to adhere to the standards which have been adopted by the agency. If you have any questions concerning the Guidelines, consult your Territory Vice President or Open communication is encouraged, so speak up. If you would like to remain anonymous you may call the Ethics Hotline at
The guidelines do not address every situation you might encounter; there is no substitute for your good judgment and common sense.

5. HealthMarkets Code of Ethics and Professional Responsibility
HealthMarkets Agents offer insurance products and are in the unique position of being the liaison between the purchasers and the suppliers of insurance products. Essential to this role is the blending of professional duty to the customers, HealthMarkets, and the Insurance Companies we represent. Ethical balance is required to avoid conflict between any of these obligations.
Therefore, I am responsible:
To hold my profession in high esteem and strive to enhance its prestige.
To preserve my customers' confidences and maintain all information as confidential. To render exemplary service to my customers.
To adhere to professional standards of conduct in helping my customers to attain their insurance objectives.
To present policies factually and accurately, providing all information necessary for the customer to make a well informed decision when buying an insurance policy.
To perfect my knowledge and skills through training and continuing education.
Each Agent is committed to the following Code of Ethics and Professional Responsibility upon signing their contract when joining HealthMarkets.

6. HealthMarkets Code of Ethics and Professional Responsibility cont.
To keep informed with respect to applicable laws and regulations and to observe them in the practice of my profession.
To only use advertising that is true and not misleading.
To report unethical behavior or wrongdoing to appropriate HealthMarkets personnel.
To be fair and just to our competitors, and not to engage in any unfair trade practices which may reflect unfavorably on HealthMarkets and my profession.
To be honest and professional in my conduct to my customers, fellow Agents and producers, HealthMarkets employees and employees of the Insurance Companies whose products we represent.
By embracing these principles, I will be dedicated to ethical behavior. I understand that this Code of Ethics is based upon the belief that through my word and actions I will bring honor to HealthMarkets, my profession, and those customers I serve.

7. Philosophy Valued relationships with agents and customers
Committed to demonstrate high standards
Ethics
Financial responsibility
Integrity
Contractually obligated
Unacceptable behavior may result in termination of the contract
HealthMarkets values our relationships with agents and customers. We believe that the reputation, culture, and tradition of HealthMarkets will attract a high-quality sales force that develops long-term relationships with its customers. We are committed to developing strong relationships of trust with our customers and expect all transactions to be conducted honestly and ethically.
All agents must demonstrate the highest standards of ethics, financial responsibility, and integrity in all dealings with customers and the insurance companies we represent. In demonstrating these standards, agents will avoid problems involving compliance and market conduct violations. Agents have a contractual obligation to conduct business by HealthMarkets’ ethical standards and must comply with guidelines, rules, procedures and policies of HealthMarkets that include but are not limited to conduct, licensing, criminal history, misrepresentation, misappropriation of funds, rebating, marketing and sales materials, churning, and product suitability.
Any behavior considered unacceptable by HealthMarkets may result in the termination of the agent’s contract. HealthMarkets will aggressively investigate any conduct that violates its policies and guidelines. Violation of these standards may also result in personal liability and loss of insurance company appointments for an agent.

8. Financial Responsibility
Agents must ensure their clients purchase what they can afford
Agents must ensure their clients fully understand the products they applied for and ultimately purchased
Agents must ensure their clients understand that health insurance is mandated and although beneficial, supplemental insurance is optional
Agents must ensure their clients understand any state or federal subsidy afforded to them applies to the household income and the impact if the household income changes
Agents should ensure their clients want and are able to purchase the products applied for during the sales presentation. It is an agent’s responsibility to communicate insurance requirements to customer as well as advising what products are optional.

9. Contract Obligations
Agents must ensure they are aware of current contract provisions and obligations.
As contracted agents, you have obligations to customers, HealthMarkets, regulatory entities and the Insurance Companies of which you market insurance products. Agents must follow all HealthMarkets and Insurance Companies’ various guidelines
Agents should utilized Insurance Company Communication sent directly to them or via HealthMarkets’ Communications and agent web portals for carrier guidelines
Agent should utilize the HealthMarkets Resource Center for Agency Guidelines
The primary source for communication from the Agency to agents is through the HealthMarkets Resource Center. Important information including a copy of the current Independent Agent Commission Only Contract , that agents need to know to run their business in compliance with HMIA’s guidelines is contained within the Resource Center. It is important to check the site regularly for announcements. The User Guide contains technical information about the website, but if you have any questions, please contact the HealthMarkets InTouch Hotline at
As insurance agents you must comply with existing and new laws. Take measures to receive communication issued from the state department of insurance regarding your requirements as a licensed agent.
HealthMarkets Agent Resource Center is the primary source for communication and the location of all pertinent business information. If you have questions contact InTouch at

10. Advertising
Advertising branded or generic used to promote the sale of insurance is subject to state and federal regulations
Agents are required to submit advertising material (branded and generic) to Compliance for review and approval prior to use. Submit material to and copy your Territory Vice President
Agents must protect HealthMarkets brand when using our logo and follow the Branding Guidelines located on the Resource Center
Agents have responsibilities for advertising and sales materials. The first course of action is touring the Agent Marketing Guidelines section on the Resource Center. You can utilize pre-approved advertising and sales materials available on the Resource Center by clicking on the Marketing Tools tab. If you create or use any sales materials, it MUST be approved by the HealthMarkets Advertising Compliance Department before being used. You must use the Resource Center to get the most current information on changes to HMIA’s guidelines, policies, and procedures, including the Agent Marketing Guidelines. If you have any questions that are not answered by the information found on the HealthMarkets Resource Center, please

11. License and Appointments
Agents are required to maintain and keep their insurance license(s) active, which includes completing continuing educational courses required by state departments of insurance
Agents agreed, upon contract with HealthMarkets, to be exclusive to us and our Affiliates and to request appointments with the affiliated insurance companies for whose products they want to market
Agents must ensure they are appointed with the carrier for any plan they present and market to a customer

12. Integrity
Is one of HealthMarkets core values and is the guiding principle for how we deal with our customers, our business relationships, our decisions and actions. Integrity means a steadfast adherence to a strict moral or ethical code.
Doing what we say we are going to do and by always conducting our business according to the highest ethical and legal standards

13. Agency Standards Progressive Discipline Policy Fraud & Forgery
Due process and discipline procedures
Consistent program for establishing agent accountability and responsibility
Fraud & Forgery
Clearly defined in the Agent Guidelines
All instances of fraud must be reported
Some examples of Fraud or Forgery would be:
An agent transferring information from a paper application to an electronic format and e-signing on behalf of the applicant
The practice of using an agent’s address as the customer/applicant contact address
Background Checks
As part of the progressive discipline policy, agents are advised of the established policies and procedures for ethical sales practices and are provided with a fair and effective process for reviewing and responding to allegations of agent misconduct. Details of the program are available via the Resource Center under Agency Standards.
Fraud is clearly defined in the agent guidelines. It includes, but is not limited to any activity that constitutes fraud or deceit, misappropriation of funds or personal property, forgery, embezzlement, or unauthorized alteration of documents. All agents have a duty to report any known fraudulent activities to their Territory Vice President or to the Ethics Hotline.
A condition of your HealthMarkets contract is granting the agency the right to conduct criminal and background checks both prior to becoming an agent, and periodically while you remain an agent with HealthMarkets. You must agree to complete any documents or paperwork reasonably required by HealthMarkets to conduct these background and criminal checks.

14. Agency Standards
HealthMarkets provides a forum for customers, insurance companies and regulatory entities to express concern and if necessary file a complaint against an agent
HealthMarkets will investigate each concern it is made aware of through a fact finding process that will include customer comments, agent comments and external resources, if necessary
Agents upon contract agreed to notify HealthMarkets of consumer complaints, insurance company investigations or any administrative/regulatory agency allegation or finding
HealthMarkets strives to exceed the industry standards for ethical principles and conduct, and to represent the agency and all insurance companies in a professional and compliant manner.

15. What is a Complaint? Definition of a Complaint Complaint Process
Complaint must be forwarded to the Insurance Company
HealthMarkets Agency Standards must be copied on correspondence
Full cooperation from agents in complaint investigations
Complaints are tracked and monitored per agent
More than 3 complaints within a 12-month rolling period is considered excessive
Agent documented discussions with customers and retention of paperwork is very important
It is the responsibility of HealthMarkets and the Insurance Companies that HealthMarkets represents to record all complaints made to them. In resolving such complaints, HealthMarkets must comply with all applicable state and federal regulations.
A complaint is a communication, usually written, but sometimes oral, in which a grievance is expressed. A grievance is the expression of indignation, annoyance, or resentment stemming from a feeling of being wronged. This definition is to be applied to all complaints received from a customer, beneficiary, or representative on behalf of either of those parties, or from a member of the general public. All agents should recognize the difference between a grievance and an inquiry.
In the course of your daily sales functions, you may receive complaints from your customers. All complaints must be forwarded to the insurance company with a copy to When an Insurance Company receives a customer complaint, they may send a letter to the Agent asking for information about the issue. HealthMarkets expects that all agents will fully cooperate in complaint investigations, and when a response and/or documentation is requested, the Agent must promptly reply to the request. Failure to cooperate with a complaint investigation OR settling a complaint without the knowledge of HealthMarkets could result in disciplinary action including termination of the Agent’s Contract.
HealthMarkets tracks and monitors complaints by agent. All complaints will be handled as outlined in the Agency Standards Section of the Agent Guidelines. As a reminder, if the number of complaints exceeds three in a 12 month rolling period, regardless or which Insurance Company is involved and whether or not the complaint is confirmed, HealthMarkets will work with the agent to address issues in an effort to avoid future complaints. HealthMarkets is committed to providing fair and expeditious handling of customer complaints and disputes.
It is very important for you to document discussions with your customers and retain any and all paperwork connected with each customer and your interactions with them.

16. How to Identify a Complaint
A written or verbal communication is considered a complaint when the customer:
Expresses dissatisfaction regarding policies, procedures or services
Alleges employee or agent misconduct
Threatens to take action as a result of his/her dissatisfaction
Demands a response or action from the Company as a result of his/her dissatisfaction
Copies a regulatory agency, government office, Better Business Bureau, and/or an attorney

17. Agent Training
HealthMarkets agent training curriculum includes appropriate techniques for point of sale presentations to special populations including the elderly, disabled, and non- or limited-English speaking person as well as:
Compliance around federal regulations such as Do Not Call requirements
Product information to ensure agents fully understand the products they market
Responsibilities of a licensed insurance agent
Functions that a non-licensed individual can do on behalf of a licensed agent
Record generation and retention requirements
All HealthMarkets agents are responsible for completing any training program required by HealthMarkets and/or any Insurance company. Training on insurance products and HealthMarkets and Insurance company guidelines may be delivered face-to-face or through an interactive web-based program. An examination may be included to test each agent’s product knowledge. HealthMarkets maintains records of agent training, attendance, and testing to provide proof of completion for an insurance company or regulatory agency who requests it. Please note that the agent training curriculum also includes appropriate techniques for Point of Sale presentations to special populations including the elderly, disabled, and non- or limited- English speaking person.

18. Federal Compliance Requirements
HealthMarkets maintains compliance with all federal requirements including
HIPAA Accountability
Anti-Money Laundering (AML)
Telemarketing Do Not Call (TDNC) Regulations
Other important legislation and regulatory requirements
All agents play a large role in the success of HealthMarkets regulatory requirements
Questions can be directed to HealthMarkets via
HealthMarkets is committed to maintaining compliance with any and all federal requirements.
HIPAA, or the Health Insurance Portability and Accountability Act of 1996 protects the health insurance coverage of workers and their families if they change or lose their job and requires the Department of Health and Human Services to establish national standards for electronic healthcare transactions and the security and privacy of health information. Both provisions protect the rights of our customers. You have a responsibility to maintain confidentiality of all your customers’ protected health information including: applications, forms, notes, and any materials that contain an insured’s name or other identifying information of the insured. You must also keep complete and accurate records of all transactions for at least 7 years. In retaining records, you must review all Insurance Company Business Guidelines and comply with each company’s record retention policy which is located under the Products Tab on the HealthMarkets Resource Center.
The US Patriot Act of 2001 and other federal laws related to the prevention of money laundering require that you be educated on the detection of money laundering activities and be responsible for carrying out certain requirements.
The Telemarketing Do Not Call policy was established October 1, 2003 by the Federal Trade Commission. It assures that phone solicitations comply with the federal and state specific DNC regulations. Violations of these regulations result in substantial fines and agents are responsible to ensure that no violations occur.
Legislation and regulatory requirements can vary by product type, so you should comply with any important state and/or federal legislation and regulatory updates.
Remember, you play a huge role in HealthMarkets’ ability to meet all regulatory requirements. If you have any questions about Compliance Requirements, contact HealthMarkets’ Compliance Unit.

19. Protecting Private Information
Customers trust HealthMarkets agents with private and secured information
Agents must secure PHI and PII which includes encrypting any device you use to conduct HMIA business
Agents are required to report the theft of technology containing secured information to local police within 24 hours
Agents are required to report any breach of secured information to within 24 hours.
Any device used by an agent to conduct HMIA business must have encryption software installed to ensure protection of customers’ personal information should loss or theft of the device occur.
Agents must ensure personal safeguards are used to protect hard copy documents containing PHI and PI. This would include ensuring that sensitive documents are stored in locked cabinets or by secured means while being transported.

20. Annual Agent Encryption of Technology Attestation
Agents are required to attest annually that they have taken measures to secure and protect personal health and identifiable information stored on computers, laptops, tablets and smart phones with appropriate encryption software. The following is the Annual Agent Encryption of Technology Attestation

21. Annual Agent Encryption of Technology Attestation
I understand that it is my responsibility to use any and all appropriate safeguards to prevent misuse, destruction, loss, alteration or disclosure of any Personally Identifiable Information (“PII”) or Personal Health Information ("PHI") as stated in my Independent Insurance Agent Commission — Only Contract and its attached Business Associate Addendum (collectively referred to as “Agent Contract”) with HealthMarkets Insurance Agency (“HealthMarkets” the d/b/a or assumed name of Insphere Insurance Solutions).

22. Annual Agent Encryption of Technology Attestation
In order to meet the obligations of my Agent Contract with HealthMarkets, I attest that I have implemented, use and will continue to use encryption software as a technical safeguard if the computer(s), back-up devices and services, and/or any mobile device(s), including, but not limited to, mobile phones, tablets, etc., are employed to receive, transmit, store and/or upload PII or PHI for business purposes. I agree to maintain required updates of the software to ensure effectiveness. I further understand that the loss of my login credentials or a failure in the software or hardware could render the data stored thereon permanently inaccessible.

23. Annual Agent Encryption of Technology Attestation
I understand that failure to meet my obligations as outlined in this Attestation and my Agent Contract may subject me to HealthMarkets’ Corrective and Disciplinary Actions process.

24. Confirmation of understanding
I understand that this training is designed to give me an overview of HealthMarkets expectations and does not address every possible situation. I agree to adhere to HealthMarkets Guidelines and that it is my responsibility to asks questions if I am not able to locate an answer to a particular issue by contacting my Territory Vice President or by ing

25. Thank you!