We're Here to Help
At Spark, compliance isn't about catching you doing something wrong — it's about making sure you and your agents have what you need to do things right. The Compliance Agency Monitoring Program (CAMP) is how we track compliance health across our agency network, spot problems early, and work with you to fix them before they become bigger issues.
This article gives you an overview of how CAMP works. Use the links at the bottom to dive deeper into any topic.
CAMP_Quick Reference Guide_V3.0.pdf
What Is CAMP?
CAMP is Spark Advisors' program for monitoring the compliance performance of all contracted agencies and their agents. Every agency in the Spark network is enrolled in CAMP automatically. It applies to all agencies — regardless of size, tenure, or how many carriers you work with.
CAMP exists because Spark, as a Third Party Marketing Organization (TPMO), is accountable to CMS and our carrier partners for how every agency and agent in our network operates. CMS regulations under 42 CFR §§ 422.2260–422.2274 and 423.2260–423.2274 require us to actively monitor marketing and sales activity conducted on behalf of Medicare Advantage and Part D plans. CAMP is how we do that — and how we help you stay on the right side of those requirements.
How CAMP Works
CAMP monitors performance at two levels:
Agency level — Spark looks at Total CTM and Founded Non-CTM rates across your agency as a whole. This determines your agency's risk tier, which affects the level of monitoring and requirements that apply to your agency.
Agent level — Every agent in your agency is also monitored individually. An agent's metrics determine whether they may be placed on Watchlist status or suspended from selling. This can happen regardless of where your agency's overall tier stands.
Both levels matter. Agent issues roll up into your agency's picture, which is why staying close to your agents' performance is one of the best things you can do for your agency.
What We Monitor
Spark tracks the following for agencies and agents:
Total Complaints to Medicare (CTMs) — Formal complaints filed with CMS by Medicare beneficiaries, tracked by agent and rolled up to the agency level
Founded Non-CTM complaints — Allegations or grievances submitted by beneficiaries directly to carriers
Call quality scores — Telephonic enrollment calls reviewed through Spark's IntelligenceX (IX) program
Carrier compliance flags — Watch list placements, corrective action plans, or notices from carrier partners
Marketing compliance — Use of approved materials, lead vendors, and scripts
Licensing and certifications — Active state licensure, AHIP, and carrier-specific certifications for all agents
Case responsiveness — Whether agents respond to open compliance cases on time
Agency Risk Tiers
Based on performance, each agency is assigned one of three risk tiers:
Tier | What It Means |
🟢 Low Risk | Your agency is in good standing. Standard monitoring applies. |
🟡 Medium Risk | Your agency has metrics at or above threshold. A Corrective Action Plan is required and additional requirements are in effect. |
🔴 High Risk | Your agency has been in Medium Risk for 90 or more continuous days. Monthly leadership review and discretionary enforcement actions may apply. |
Tiers are evaluated at the start of each month. Off-cycle reviews can happen at any time if a carrier escalation, case spike, or compliance event warrants it. See Understanding Your Agency Risk Tier for the full breakdown.
Agent Enforcement States
Individual agents can be placed in one of the following states, independent of your agency's tier:
Watchlist — The agent has elevated metrics but hasn't hit the suspension threshold yet. Your agency is responsible for coaching.
Suspended — The agent has met the suspension threshold and is removed from active selling for a minimum of 30 days.
Hardstop / Termination — Reserved for serious violations like fraud or direct beneficiary harm. Effective immediately.
Your Responsibilities as an Agency Partner
You play a critical role in keeping your agency compliant. Here's what that looks like day to day:
Keep all agent licenses and certifications current
Submit required compliance documents on time
Respond to open compliance cases within the required timeframe
Coach agents who are placed on Watchlist status
Uphold agent suspensions — suspended agents must stop all selling activity
Submit all marketing materials and scripts to Spark for carrier approval before use
Report potential compliance issues to Spark as soon as you're aware of them
The earlier you flag a concern, the more we can help. Don't wait for something to become a formal complaint before reaching out.
Questions?
Reach Spark's compliance team directly at [email protected].
For a full breakdown of thresholds, tier criteria, and requirements, refer to the CAMP Quick Reference Guide attached to this article.
Last reviewed: April 2026
Disclaimer: This article is for informational purposes only and reflects Spark Advisors' CAMP policies as of the date of last review. Program thresholds, metrics, tiers, and procedures are subject to change. Spark Advisors reserves the right to update, modify, or discontinue any element of the CAMP program at any time. This article is not legal advice. Agency partners are responsible for maintaining compliance with all applicable CMS regulations, carrier requirements, and federal and state law. Questions? Contact your Account Manager or email [email protected].