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 performance across our agency network, spot problems early, and work with you to fix them.
Download the full Spark_Agency_Agent_Compliance_Guide_V4_0.pdf.
Download Spark_Agency_Agent_Compliance_Metrics_Aug 2026.pdf
What Is CAMP?
CAMP applies to every agency and agent in the Spark network, regardless of size.
As a Spark agency, you operate as a First-Tier, Downstream, or Related Entity (FDR) under the Medicare Advantage and Part D programs. Beyond CAMP, you have an independent duty to maintain your own CMS-compliant compliance program under 42 CFR §§ 422.503(b)(4)(vi) and 423.504(b)(4)(vi). CAMP tracks your performance against Spark's own monitoring criteria — it does not substitute for, or relieve you of, that separate FDR obligation. See "Compliance Program Requirements for Agencies" for the full FDR breakdown.
Spark and the applicable carrier may audit your compliance program, policies, records, call recordings, marketing materials, or enrollment practices at any time, with or without advance notice. You must cooperate fully with any such audit.
How CAMP Works
CAMP monitors performance at two independent levels:
Agency level — Spark tracks a set of rate-based metrics across your agency as a whole. This determines your agency's risk tier and monitoring status.
Agent level — Every agent is evaluated individually and can be suspended regardless of where your agency's overall status stands. Terminated agents' metrics are excluded from agency-level rates.
Agency-Level Metrics
Metrics are channel-specific — Call Center and Field carry different Expectation and Threshold levels. CTM Rate and Founded Non-CTM Rate are primary triggers: crossing either channel's Threshold moves your agency into Enhanced Monitoring. Accretion Rate, RDR, and Call Quality Average are supporting metrics — they shape what goes into a Corrective Action Plan once you're in Enhanced Monitoring, but do not independently trigger it.
Call Center Channel
Metric | Window | Expectation | Threshold |
CTM Rate | 12M rolling | < 2.0 per 1,000 | 2.0 per 1,000 |
Founded Non-CTM Rate | 12M rolling | < 10.0 per 1,000 | 10.0 per 1,000 |
Accretion Rate | 3M rolling | ≥ 90% | < 80% |
RDR | 3M rolling | ≤ 10% | ≥ 20% |
Call Quality Average | 30-day | ≥ 90% | < 85% |
Rates are per 1,000 enrollments. The passing Call Quality score for an individual call is 85%.
Field Channel
Metric | Window | Expectation | Threshold |
CTM Rate | 12M rolling | < 0.8 per 1,000 | 0.8 per 1,000 |
Founded Non-CTM Rate | 12M rolling | < 3.5 per 1,000 | 3.5 per 1,000 |
Accretion Rate | 3M rolling | ≥ 94% | < 85% |
RDR | 3M rolling | ≤ 5% | ≥ 15% |
Call Quality Average | N/A | N/A | N/A |
Call Quality Average does not apply to the Field channel.
Agent-Level Metrics
Each agent is evaluated individually and can be suspended regardless of your agency's overall monitoring status.
Metric | Window | Expectation | Threshold |
Total CTM Count | 12M rolling | < 6 | ≥ 6 |
Founded Non-CTM Count | 12M rolling | < 10 | ≥ 10 |
Accretion Rate | 3M rolling | ≥ 90% | < 80% |
Rapid Disenrollment Rate (RDR) | 3M rolling | ≤ 5% | ≥ 15% |
Call Quality Score | 30-day | ≥ 90% | < 85% |
Response Timelines
Every compliance case — CTM or Non-CTM — must be answered by the deadline Spark sets and communicates with the case. That deadline is typically 5 business days, but may be shorter or longer depending on the applicable carrier. This applies regardless of your agency's monitoring status or an agent's suspension standing.
IMPORTANT: Missing the deadline results in an "Unresponsive" determination, which triggers agent suspension independently of the monthly monitoring cycle.
Monitoring Levels & Risk Tiers
Standard Monitoring covers Low Risk agencies. Enhanced Monitoring covers both Medium Risk and High Risk agencies — Spark applies different requirements within Enhanced Monitoring depending on your risk level.
Risk Level | Monitoring Status | How You Get Here | Requirements | Notified? |
🟢 Low Risk | Standard Monitoring | Both primary metrics below Threshold for your channel, no unresolved obligation violation | None | No |
🟡 Medium Risk | Enhanced Monitoring | In Enhanced Monitoring, but doesn't meet a High Risk condition | Corrective Action Plan (CAP), contents set by Spark | Yes, written notice |
🔴 High Risk | Enhanced Monitoring | 90+ days in Enhanced Monitoring, OR exceeds both primary metrics at once, OR exceeds a carrier's own compliance cap, OR has agent suspensions/terminations | CAP, typically more intensive requirements | Yes, written notice |
You enter Enhanced Monitoring when your CTM Rate or Founded Non-CTM Rate reaches your channel's Threshold, when a marketing violation goes unremediated, or when you violate FDR, call quality, or marketing/script obligations. Accretion Rate, RDR, and Call Quality Average do not independently trigger Enhanced Monitoring.
You exit Enhanced Monitoring once every assigned CAP item is completed and verified by Spark. For rate-driven cases, both metrics must also clear your channel's Threshold. Spark determines when a CAP is resolved — there is no fixed timeline.
Possible CAP items — Spark tailors each CAP to the specific issue and may draw on any combination of:
Increased documentation and reporting
Enhanced call quality oversight, including a required minimum call quality score
Marketing and script remediation
Targeted coaching at the agency or individual agent level
Operational adjustments — such as a pause on co-op payments, restrictions on onboarding new sub-agencies or agents, or an adjusted requirement for Spark-sourced leads
Leadership-level review of your progress for the duration of the CAP
In the most severe cases — where a CAP isn't addressed or the underlying issue is serious enough — Spark may take discretionary action up to and including a permanent reduction in co-op rate or suspension from the Spark network. These require Spark leadership approval.
Agent Enforcement States
| 🔴 Suspended | ⛔ Hardstop / Termination |
Effective | 3 business days after notice | Immediate, outside the monthly cycle |
Applies when | Agent meets suspension thresholds, or is Unresponsive | May include fraud, unlicensed sales, or direct beneficiary harm — not limited to these |
Agency must | Uphold the suspension. The agent is suspended in Sunfire but retains Spark Platform access. | Contact Spark Compliance directly. No standard enforcement sequence applies. |
Suspension coaching and reinstatement — there is no automatic reinstatement. Required coaching must be completed and verified.
Suspension | Length | Coaching Requirement | Lifts When |
First suspension | 5 days | Completed at the agency level. Agency submits a coaching form to [email protected]. | Coaching form is submitted and confirmed complete. |
Second and subsequent | 30 days | Conducted directly with Spark Compliance, not at the agency level. | Coaching with Spark Compliance is completed and verified resolved. |
TIP: Failure to complete required coaching within the suspension period may prolong the suspension at either tier. Agents keep Spark Platform access throughout a suspension — only Sunfire access is revoked. Upon reinstatement, CTM Count and Founded Case Count reset to zero for Spark Compliance tracking, though carriers may act independently based on full history. Improvement in Accretion Rate and RDR is considered in the reinstatement decision.
Call Quality & Marketing Obligations
These apply to every agency and agent, regardless of monitoring status. Violating them can independently trigger Enhanced Monitoring:
Record every marketing, sales, and enrollment call in full, including the audio portion of virtual-platform calls. If a beneficiary objects to being recorded, the call must end — there's no exception that allows the call or sale to continue unrecorded.
Use only Spark- and carrier-approved sales and enrollment scripts.
Deliver the required TPMO disclaimer verbally before any discussion of plan benefits begins. Effective October 1, 2026 (CY2027 marketing), this replaces the prior "within the first minute" standard.
Complete a Scope of Appointment (SOA) before any personal marketing appointment. Effective October 1, 2026, the mandatory 48-hour wait between SOA completion and the appointment is eliminated — the SOA itself is still required before any plan-specific discussion, and in-person appointments require a written SOA.
Independently score at least 2 calls per agent per month as part of your own internal quality assurance process, separate from Spark's own call quality monitoring.
Submit all marketing materials, sales scripts, and agent-facing materials to Spark for carrier approval before use. Approved materials must be resubmitted at least annually, and any change — no matter how minor — requires resubmission before use.
Spark monitors agency call quality through the IntelligenceX (IX) platform, with ongoing randomized review of enrollment calls calibrated to your monitoring status.
Need Help?
Reach Spark's compliance team at [email protected], or see "Contact Spark Compliance" for office hours and live support.
Last reviewed: September 2026
Disclaimer: This article reflects Spark Advisors' compliance monitoring standards as of the date of last review. Program thresholds, metrics, tiers, and procedures are subject to change. Insurance carriers set and enforce their own compliance metrics and standards independently of Spark, and those standards may change 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.