Overview
For Medicare agents, moving from one agency to another—or even changing your contracting hierarchy—is not a simple administrative update. It requires going through a structured process known as a release request, which is often misunderstood.
This guide provides a detailed breakdown of the release process, including how it works, who controls it, what documentation is required, and what to expect at each stage. Each section reflects how releases are actually handled in practice.
What a Release Request Is and When It’s Required
A release request is the formal process that allows a Medicare agent to move their carrier contracts from one agency or top-of-hierarchy (TOH) to another.
When an agent is contracted under an existing hierarchy, that structure is recognized and controlled by the carrier. Because of this, the agent cannot independently move their contracts. The agent must first be released by their top-of-hierarchy before they can contract under a new hierarchy.
Agents typically need to request a release when they are:
Moving their existing carrier contracts to a new agency or top-of-hierarchy
Changing the hierarchy they are contracted under
Joining a different FMO, IMO, or agency structure
Transferring their book of business or writing rights to a new organization
While these scenarios may feel operationally different, they all require the same foundational step: approval from the current hierarchy.
Knowing what to request: What is the difference between releases and terminations?
A Release allows an agent to move their existing carrier contract to a new agency/top-of-hierarchy. Once the release is approved by the current top-of-hierarchy and processed, the agent can continue writing business with that same carrier under the new top-of-hierarchy (carrier-dependent, but that’s the general expectation).
A Termination is the removal of an agent from a carrier contract entirely. Once the carrier processes the termination, the agent no longer has access to that carrier and cannot write business under that contract. If they want to work with that carrier again, they typically need to re-contract, and depending on the carrier, this may involve a waiting period.
Types of Releases and How Carrier Rules Affect the Process
Not all releases are handled in the same way, and understanding the distinction is critical.
There are three primary types of releases agents should be aware of:
Carrier-specific releases
Some carriers require a separate release form for each individual carrier contract. This means an agent may need to complete multiple release processes if they are contracted with multiple carriers.
Hierarchy releases
In some situations, the agent’s top-of-hierarchy releases them from the entire hierarchy, allowing all contracts under that structure to move.
Reciprocal releases
This is requested when an agency wants Spark to sign an agreement that says the agent can move to Spark but also return to the original agency without any repercussions.
The key point is that carrier rules vary, and those rules determine which type of release is required. There is no universal standard across carriers.
Once a release is approved, it typically allows the agent to:
Contract under a new agency or hierarchy
Write new business under that structure
Receive commissions through the new hierarchy
However, the exact outcome depends on the carrier’s policies.
Even after approval, agents may still encounter waiting periods or blackout restrictions that affect when the change becomes active.
Top-of-Hierarchy
At the center of every release request is the top-of-hierarchy (TOH), also commonly referred to as an upline.
The TOH is the agency at the highest level of the agent’s contracting structure with a carrier. Because the carrier recognizes this organization as the controlling entity, only the TOH has the authority to approve or grant a release.
This has several important implications:
The release decision is not managed by the agent alone
Carrier systems will only recognize a release from the correct TOH
For agents who are unsure who their TOH is, there are several reliable ways to identify it:
Reviewing original contracting paperwork
Checking the carrier portal
Contacting the current agency
Contacting the carrier directly
If an agent does not have contact with their previous top-of-hierarchy, Spark’s Support Team ([email protected]) or the carrier can help provide the name of the top-of-hierarchy, but they still cannot act on the agent’s behalf.
Understanding Spark’s Role in the Release Process
A major source of confusion in the release process is misunderstanding Spark’s role.
Spark acts as a guide and support resource, helping agents understand and navigate the process, but Spark is not the party that controls or approves releases.
Spark can assist with:
Explaining how the release process works
Helping agents identify their top-of-hierarchy
Providing carrier-specific instructions for requesting a release
Helping determine which carriers require a release
Answering questions about hierarchy changes or contracting steps
Troubleshooting issues if the process becomes unclear or delayed
However, there are strict limitations to what Spark can do. Spark cannot:
Request a release on an agent’s behalf
Approve or deny a release
Force another agency to grant a release
Override carrier hierarchy rules or waiting periods
Submit release documentation to carriers
Provide copies of signed releases between agents and their previous top-of-hierarchies.
Provide a release for carriers that an agent is not Ready to Sell with
These limitations exist because releases are agreements between the agent, their current hierarchy, and the carrier. Spark is not part of that agreement and does not control any external hierarchy.
Additionally, once Spark sends a release document to an agent’s current top-of-hierarchy for review, the document is no longer managed by Spark. Any signed copies must be requested directly from the top-of-hierarchy or the carrier.
Why the Process Cannot Be Bypassed
The release process follows a strict flow for a reason.
Carrier contracting systems are designed to:
Properly align hierarchy structures
Ensure compliance with contracting rules
Properly assign commissions
Because of this, releases must move through a defined approval path:
Be initiated within the current hierarchy
Be approved by the top-of-hierarchy
Be processed by the carrier
Spark cannot bypass or accelerate this structure.
Documentation Requirements and Common Pitfalls
Release requests are highly dependent on proper documentation, and errors here are one of the most common causes of delays.
Most releases require a signed release form authorizing the agent to be released from their current hierarchy.
Depending on the carrier, required documentation may include:
A carrier-specific release form
A signed letter of release from the current top-of-hierarchy
A release request submitted through a carrier portal
Additional contracting forms if the change is part of a new appointment
At a minimum, release documentation must include:
Agent name
NPN
Top-of-hierarchy signature
A timestamp (all releases must be time-stamped)
Carrier-specific requirements are especially important. For example, some carriers require:
Their own release form template
Submission through a portal
The release to come directly from the TOH
Submission to a specific contracting or licensing inbox
There are also special requirements for certain carriers. For example:
Aetna requires wet signatures (handwritten signatures)
Some carriers require releases to be submitted directly by the TOH rather than the agent
Some enforce holding periods before the release becomes effective
See Requesting a Release for more information.
Common Documentation Mistakes
The most frequent issues that delay release requests include:
Missing NPN or agent information
Release forms not signed by the correct TOH
Using the wrong carrier release form
Submitting electronic signatures when wet signatures are required
Sending forms to the wrong carrier inbox
Missing dates or incomplete fields
Carefully reviewing documentation before submission is one of the most effective ways to prevent delays.
Submitting the Release: Responsibility and Process
Submitting the release is the responsibility of the agent or the current top-of-hierarchy.
Because the release is an agreement between those parties, carriers typically require the documentation to come directly from them. Spark does not submit release requests on behalf of agents.
See Requesting a Release for more information.
The Standard Submission Flow
While each carrier may have slight variations, the general process includes:
Confirming whether the carrier requires a release
Identifying the current top-of-hierarchy
Completing the required release form or documentation
Ensuring all required information is included
Submitting the release to the carrier using the correct method (email, portal, or contracting team)
Waiting for the carrier to process and update the hierarchy
If an agent is unsure about carrier-specific steps, Spark can provide guidance—but the submission itself must come from the appropriate party.
Typical Release Process (When Spark Is the Top-of-Hierarchy)
When Spark is the top-of-hierarchy (TOH), the release process follows the same overall structure, but there are a few important differences in how the early steps are handled and how Spark is involved.
In this scenario, Spark is the entity that sits at the highest level of the agent’s contracting hierarchy with the carrier. Because of that, Spark may play a more direct role in helping initiate and route the release, but it’s important to understand that Spark still does not control the full process from start to finish.
Ultimately, even when Spark is the top-of-hierarchy, the release process still follows the same required flow:
Agent requests a release from their current top-of-hierarchy
The agent must first notify their current agency or top-of-hierarchy that they would like to be released.
The top-of-hierarchy submits a release request form to Spark
The top-of-hierarchy provides the agent’s details (such as name, NPN, and carriers) and confirms approval to begin the release process.
Spark reviews and prepares the release
Spark’s contracting team reviews the request and prepares release documentation for carriers that Spark manages directly.
Spark sends the signed release to the requesting agency/top-of-hierarchy
Release documents are exchanged between agencies and are not sent directly to the agent.
The carrier processes the release and updates the hierarchy
Once submitted, the carrier reviews the request and updates the agent’s hierarchy based on their internal timelines and rules.
Important:
Even when Spark is the top-of-hierarchy, the process still depends on:
The top-of-hierarchy approving and participating in the request
The required signatures being completed
The carrier’s processing timeline
Spark can support and complete its portion of the process, but it does not control the full release timeline or final outcome.
The key difference is that Spark can provide more direct support at the beginning of the process—but it does not override the roles of the top-of-hierarchy or the carrier at any stage.
When an agent is leaving an agency within the Spark hierarchy, the responsibility for the release still sits with:
The agent, and/or
The top-of-hierarchy (Spark)
In practice, this means Spark can help facilitate the early stages of the process by preparing or providing the appropriate release documentation and ensuring it is directed to the correct party for approval.
Once the release document is prepared, Spark may send it to the agent’s current top-of-hierarchy for review and signature. At that point, however, the process begins to move outside of Spark’s control. The top-of-hierarchy is responsible for signing the release, and the carrier is responsible for processing it.
Even in cases where Spark is the TOH, the process still depends on:
The appropriate signatures being completed
The correct submission to the carrier
The carrier’s internal processing timelines and rules
For carriers within the Spark hierarchy, Spark generally attempts to provide releases within one business week, assuming all required information is available. However, this timing applies only to Spark’s portion of the process and does not guarantee when the full release will be completed.
After the release is sent for signature, Spark does not retain control over the document or the outcome. If an agent needs:
A copy of the signed release
Confirmation that it has been submitted
Additional releases for carriers that are managed by the top-of-hierarchy, that are not Spark
Updates on processing status
They will need to contact their current top-of-hierarchy or the carrier directly, as those parties manage the approval and submission steps.
Timelines, Processing Delays, and Blackout Periods
Release timelines vary widely depending on both the carrier and the hierarchy involved.
In general, most releases take anywhere from a few days to several weeks after submission.
The timeline is primarily controlled by:
The top-of-hierarchy, who must approve or sign the release
The carrier, who processes and updates the hierarchy
For Spark carriers, Spark attempts to provide releases within one business week, but the overall timeline is still dependent on these external parties.
Blackout Periods
A key factor that can delay releases is a blackout period—a timeframe during which carriers will not process release requests or hierarchy changes, even if documentation is complete.
These periods often occur during:
Annual Enrollment Period (AEP)
High-volume sales periods
Carrier system updates or compliance reviews
Contracting freeze windows
During a blackout period, agents must wait until the restriction is lifted before the release can be processed.
Can Releases Be Expedited?
In most cases, releases cannot be expedited.
Spark cannot speed up approvals or carrier processing, but it can help by:
Providing accurate carrier instructions
Confirming whether a blackout period is in effect
Ensuring documentation is complete and correct
Helping identify the correct submission process via a carrier portal
What Happens After Submission
Once a release is sent to the agent’s current top-of-hierarchy for review and signature, the process moves outside of Spark’s control.
At that point:
The top-of-hierarchy is responsible for approving and returning the document to the agent who requested the release
Once the release is sent to the carrier, the carrier is responsible for processing the request
If an agent needs:
A copy of the signed release
Confirmation of submission
Status updates
They must contact their top-of-hierarchy or the carrier directly.
Notification and Next Steps
In most cases, the carrier or the current top-of-hierarchy will notify the agent once the release has been processed.
After approval, the agent should:
Begin or complete contracting with the new hierarchy
Submit any required carrier onboarding or contracting documentation
Where Is My Release in the Process?
Release requests involve multiple steps and parties, and delays often depend on where the request is in the process.
Before the Release Is Submitted to Spark
In many cases, delays happen before Spark is involved.
This usually means:
The top-of-hierarchy has not submitted the release request form to Spark
The top-of-hierarchy has not yet approved the release
The agent has not yet formally requested the release
At this stage, Spark does not have visibility into the request.
Next step: Contact your current top-of-hierarchy to request the release and confirm the form has been submitted.
If Your Top-of-Hierarchy Does Not Approve
If your top-of-hierarchy declines the release, Spark cannot override that decision.
Depending on the carrier, you may still be able to:
Submit an Intent to Move
Complete a waiting period (typically 90 days) before transferring
See When a Release is Not Granted: The 90-Day Option (located below) for more details.
After the Release Is Submitted to Spark
Once the request is submitted, Spark will review and process releases for carriers where Spark is the direct top-of-hierarchy.
This step typically takes up to one business week, if all information is complete
After the Release Leaves Spark
Once the release has been signed and sent out:
The top-of-hierarchy and/or carrier manages the next steps
Spark no longer controls the status or timeline
Next step: Contact your top-of-hierarchy or the carrier for updates.
When a Release Is Not Granted: The 90-Day Option
If a release is not approved by the current top-of-hierarchy, the agent still has an alternative path: a no-release transfer.
This is initiated by submitting an Intent to Move.
How the 90-Day Waiting Period Works
Once an Intent to Move is submitted:
The agent enters a waiting period (typically 90 days)
The agent remains in their current hierarchy during that time
The current top-of-hierarchy continues to receive credit for business written
The agent can continue writing business
After the waiting period ends, the carrier typically processes the transfer to the new hierarchy.
Key Distinction
Transfer with release → Immediate move (subject to carrier processing)
Transfer without release → (typically) 90-day waiting period
This timeline may be extended if blackout periods apply, depending on the carrier.
Common Misunderstandings and Friction Points
Several recurring misconceptions lead to confusion and frustration among agents:
Believing Spark controls the release process
Assuming Spark can force or override a release
Expecting immediate transfer after a release is signed
Thinking carrier rules can be bypassed
In reality:
Releases must come from the correct top-of-hierarchy
Spark does not retain signed release documents
Carrier policies—including blackout periods and waiting periods—always apply
Each carrier may have different requirements and processes
Best Practices to Make the Process Smoother
Agents who approach the release process with preparation tend to experience fewer delays.
Before requesting a release, agents should:
Confirm whether a release is required (not all carriers require one)
Check the carrier portal first—many carriers allow direct submission (e.g., HealthSpring, Molina, Clover, Wellcare)
Review the carrier’s transfer policy, including Intent to Move options
Ensure they are ready to contract with the new hierarchy
During the process, agents should:
Identify their top-of-hierarchy early
Communicate directly with their current top-of-hierarchy in advance
Follow carrier-specific instructions carefully
Ensure all required information (NPN, signatures, carrier name, dates) is included
Taking these steps early helps reduce delays and prevents the need to resubmit documentation.
Final Perspective
The release process can feel complex, but it follows a clear structure once you understand the roles involved.
Every release depends on three key parties:
The agent
The current top-of-hierarchy
The carrier
Spark plays an important role in guiding agents through the process, but it does not control final approvals, submissions, or outcomes.
Understanding that distinction—and preparing accordingly—is what allows agents to navigate releases efficiently and with fewer surprises.