Compliance Agency Monitoring Program (CAMP)

Updated: January 2026

Spark is committed to partnering with agencies and agents to market Medicare products in a compliant, ethical, and beneficiary-focused manner. Our compliance program is designed to begin before onboarding and continue throughout the lifecycle of our partnership, supporting agencies at every stage—from readiness and launch through ongoing growth.

As a Third-Party Marketing Organization (TPMO), Spark maintains oversight of downstream partners to ensure compliance with CMS and insurance carrier requirements. At the same time, Spark views compliance as a shared responsibility and works collaboratively with agencies to establish strong practices, identify risk early, and address issues before they escalate.

This guide outlines the framework Spark uses to support compliant distribution, monitor for risk, and engage with agency partners on remediation when needed. Our shared goals are to protect beneficiaries, support sustainable growth, and maintain a high-quality distribution channel.

Monitoring under this program is corrective and preventative. Its purpose is to identify and manage risk early, not to assign blame. Placement into a monitoring tier reflects a determination that risk exists and must be actively managed in partnership with the agency.

Compliance oversight is continuous and does not begin or end at a single point in time. Neither low complaint volume, favorable metrics, nor prior monitoring outcomes create a safe harbor.

Spark may initiate monitoring, require corrective action, or escalate oversight at any time based on factors including, but not limited to:

Spark’s oversight approach is risk-based and holistic, considering performance, trends, and engagement over time.

Spark evaluates compliance risk using a rolling twelve-month view of founded case activity combined with a qualitative assessment of behavior, trends, and controls.

Risk evaluation considers, among other factors:

Prior to contracting, Spark conducts a pre-onboarding readiness review for certain prospective agency partners. The purpose of this review is to ensure agencies are positioned for compliant onboarding and long-term success on the Spark platform.

The review applies to:

Agencies may be asked to complete a brief questionnaire and provide supporting materials to support onboarding.

Based on the review, Spark will determine onboarding requirements and next steps.

In some cases, additional onboarding support, or enhanced monitoring may be required.

This process is designed to identify potential compliance risks early and support a smooth, compliant start with Spark.

An agency becomes eligible for agency-level monitoring when:

There are no minimum enrollment or production thresholds for monitoring. Eligibility is based on risk, not size.

Spark applies a three-tier framework to reflect increasing levels of agency compliance risk. Tier status is evaluated at the beginning of each month using a rolling 12-month case rate, along with qualitative risk factors.

Spark may conduct off-cycle tier evaluations when material changes occur, including but not limited to:

Case rate thresholds establish baseline tier placement; however, severity, trend analysis, beneficiary impact, and external requirements may influence tier assignment, regardless of numeric thresholds or evaluation timing.

For purposes of tier reassessment and Corrective Action Plan (CAP) evaluation, Spark evaluates Meaningful Improvement based on whether corrective actions have resulted in a sustained and measurable reduction in compliance risk over time. Assessment is outcome-based and considers both quantitative and qualitative indicators, including changes in applicable case rates, error frequency, issue severity, and trend stability.

Meaningful Improvement requires evidence that corrective measures are effectively implemented, consistently applied, and embedded into ongoing agency operations such that recurrence of the identified compliance issues is prevented. Improvement must be demonstrated across multiple evaluation periods and may not be established by short-term performance gains, isolated corrective actions, or administrative completion of CAP requirements alone.

The presence of continued adverse beneficiary impact, the emergence of new high-risk findings related to the original compliance concern, or failure to sustain improvements may preclude a finding of Meaningful Improvement and result in continued or escalated monitoring.

Agencies are responsible for the direct supervision and performance of their agents. Spark supports this responsibility through a separate agent-level compliance monitoring framework designed to proactively identify and address individual risk.

When an agent's performance indicates elevated compliance risk, they may be flagged for additional oversight or other corrective pathway in coordination with agency leadership. This applies to all agencies, not just those within an enhanced monitoring tier.

This process is designed to:

Agents who do not demonstrate improvement, or who present significant risk, may be subject to further enforcement actions, up to and including termination.

Tier 2 is intended to address elevated agency-level risk through a collaborative and structured process.

When an agency enters Tier 2, Spark Compliance will issue a Corrective Action Plan (CAP) based on trend and root cause analysis. The CAP will define required actions, milestones, and evidence expectations. Agencies are responsible for executing the CAP and documenting their progress.

Examples of CAP requirements may include, but are not limited to:

Progress is evaluated based on meaningful improvement. If such improvement is not demonstrated, the agency’s status will be reviewed for potential escalation.

Tier 3 applies when compliance risk is sustained, significant, or unresolved through Tier 2 monitoring.

In this tier, Spark will issue an Enhanced Corrective Action Plan (CAP) with heightened requirements, and executive-level engagement from the agency is required. The Enhanced CAP is designed to immediately mitigate risk, prevent further beneficiary harm, and drive rapid, sustainable compliance improvements.

Spark will evaluate progress toward Meaningful Improvement on an ongoing basis. If Meaningful Improvement is not demonstrated within sixty (60) days, Spark may impose additional actions, which may include:

Compliance investigations may be initiated by Spark, an insurance carrier, and/or CMS, and may include (but are not limited to) cases, CTMs, grievances, allegations, call monitoring findings, marketing concerns, or enrollment-related issues.

For all telephonic enrollments, Spark requires a minimum call quality score of 80%. Call recordings must be available for review and quality assessment.

Where Spark lacks direct system access to monitor telephonic enrollment calls, agencies must meet all reporting and call submission requirements. This includes timely submission of call recordings and supporting documentation as requested.

Failure to comply with telephonic enrollment call access and submission requirements may result in agent termination recommendations and agency escalation.

All marketing materials, sales scripts, and agent-facing materials used to promote Medicare products must be submitted to Spark Compliance for written approval prior to use. This includes, but is not limited to, sales scripts, marketing presentations, printed materials, digital content, advertisements, and promotional items.

Materials may not be used until they have been approved by Spark and the applicable insurance carriers, and where required, approved by CMS and formally opted into by the carrier.

All approved materials must be resubmitted for review and re-approval at least annually. Any changes to previously approved materials—regardless of how minor—require resubmission and approval before use.

Use of unapproved, modified, or expired materials is considered a material compliance violation and may result in immediate corrective action, including agent suspension and agency escalation.

Spark maintains the Compliance Monitoring Program described in this guide to fulfill its obligations as a Third-Party Marketing Organization (TPMO) under the Medicare Advantage (Part C) and Prescription Drug (Part D) programs.

CMS requires organizations that market Medicare products through downstream entities to maintain active, risk-based oversight, to identify non-compliance early, and to take timely corrective action when issues are identified. Spark's monitoring, escalation, and enforcement framework is designed to meet these expectations in a consistent and defensible manner.

This appendix summarizes the regulatory basis for Spark's program and explains how Spark's operating model aligns with CMS oversight principles.

CMS regulations require organizations that delegate marketing and enrollment activities to downstream entities to ensure those entities comply with all applicable Medicare requirements.

Under 42 CFR §422.504 (Medicare Advantage) and 42 CFR §423.505 (Part D):

As a TPMO, Spark is expected to function as an extension of the sponsor's compliance program with respect to marketing and enrollment activities. This includes maintaining documented oversight processes and demonstrating that identified risks are actively managed.

CMS does not prescribe a single monitoring model. Instead, CMS expects TPMOs to implement risk-based oversight that is proportionate to:

Spark's program reflects this expectation by:

This approach aligns with CMS guidance emphasizing early detection, trend analysis, and sustained remediation, rather than reactive enforcement alone.

CMS expects TPMOs to take timely and effective corrective action when non-compliance is identified. Corrective action must be more than advisory; it must be structured, documented, and outcome-focused.

Spark's use of Corrective Action Plans (CAPs):

When corrective actions do not result in meaningful improvement, CMS expects escalation, which may include operational restrictions or termination of downstream relationships. Spark's tier progression framework is designed to meet this expectation.

CMS oversight expectations apply not only at the organizational level, but also at the individual agent level, particularly where agent behavior presents direct risk to beneficiaries.

Spark's agent-level monitoring framework supports CMS expectations by:

Agent-level monitoring is a critical component of Spark's overall compliance posture and supports both beneficiary protection and agency-level stability.

CMS and Medicare sponsors impose strict timelines for responding to complaints, allegations, and audit inquiries. Failure to respond promptly or completely may result in regulatory findings or enforcement action.

Spark's investigation response requirements are designed to ensure that:

Timely cooperation from agencies and agents is essential for Spark to meet these obligations.