Overview
Your agency's risk tier tells you where your agency stands under CAMP. It's based on your agency's compliance performance and determines what level of monitoring and requirements apply to you.
Tiers are not permanent — they reflect your performance at a point in time and can go up or down as your metrics change. This article explains what each tier means and what it takes to move between them.
The Three Tiers
🟢 Low Risk — Good Standing
Your agency's metrics are in good shape. Standard CAMP monitoring applies and there are no additional requirements in effect.
What applies at Low Risk:
Routine monitoring of your CTM rate, non-CTM case rate, call quality, and carrier flags
Standard documentation and marketing submission requirements
Normal co-op payment processing
No restrictions on new agent or sub-agency onboarding
Monthly reports on any agent Watchlist notices or suspensions
How to stay here: Keep agent certifications current, submit documents on time, respond to compliance cases promptly, and stay close to your agents' individual metrics. Most agency tier escalations start with agent-level issues that weren't caught early enough.
🟡 Medium Risk — Elevated Monitoring
Your agency has one or both rate metrics at or above threshold, with a minimum of 6 total founded cases. Additional requirements are now in effect and a Corrective Action Plan (CAP) is required.
What applies at Medium Risk:
A written Corrective Action Plan (CAP) outlining steps to bring your metrics back below threshold
100% AI call quality scorecarding of your agency's calls through Spark's IX program
Co-op payments are paused (accrual continues — payments resume when you return to Low Risk). Effective June 1, 2026.
New sub-agency onboarding requires Spark approval
Monthly reports on any agent Watchlist notices or suspensions
How to get back to Low Risk: Both your CTM Rate and your Founded Non-CTM Rate must fall below threshold. There is no time-based exit — rate improvement is the only path back.
If you have questions about your CAP or need help understanding what's driving your metrics, reach out to [email protected]. We want to help you get back to good standing.
🔴 High Risk — Active Enforcement
Your agency has been in Medium Risk for 90 or more continuous days. High Risk is not a passive status — Spark leadership reviews your agency every month and makes an active decision about next steps.
What applies at High Risk:
All Medium Risk requirements remain in effect
Monthly Spark leadership review of your agency's status
New agent onboarding is restricted
Discretionary actions may be imposed, including a permanent co-op rate reduction or suspension from the Spark network
All discretionary actions require Spark leadership approval before they are executed
How to move out of High Risk: Return to Medium Risk thresholds. Spark leadership makes this determination monthly.
What Sets Your Tier
Your tier is based on two metrics, measured on a rolling 12-month basis:
Metric | Low Risk | Medium Risk |
Total CTM Rate per 1,000 enrollments | < 2 | ≥ 2 |
Founded Non-CTM Case Rate per 1,000 enrollments | < 10 | ≥ 10 |
The worse of the two metrics sets your tier. If either metric is at or above threshold, your agency is at Medium Risk. Both metrics must be below threshold to be at Low Risk.
Rate-based metrics can only trigger a tier change once your agency has at least 20 total founded cases on record. Medium Risk entry requires a minimum of 20 total founded cases. This protects smaller agencies from being penalized by rates based on a very small number of cases.
How Tier Changes Are Communicated
Formal tier evaluations happen at the start of each month. If your tier changes, you will receive a written notice via email identifying your current tier, the metrics that triggered the change, and your required next steps.
Low Risk agencies are not notified of their status unless a separate compliance issue comes up.
Off-cycle tier changes can happen at any time — for example, following a significant carrier escalation or a sudden spike in complaints.
Questions?
Email [email protected].
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].