Overview
Your agency's risk tier is based on two rate metrics that Spark tracks on a rolling 12-month basis. Knowing how these metrics work — and what drives them — puts you in the best position to stay in good standing and catch problems early.
The Two Metrics That Set Your Tier
1. Total CTM Rate per 1,000 Enrollments
What it is: The rate of Complaints to Medicare (CTMs) across your agency, calculated as the number of founded CTMs per 1,000 enrollments over a rolling 12-month window.
The threshold:
Low Risk: fewer than 2 Total CTMs per 1,000 enrollments
Medium Risk: 2 or more Total CTMs per 1,000 enrollments
Why it matters: CTMs are formal complaints filed with CMS. They carry significant weight with both CMS and carrier partners, and a high CTM rate is one of the most serious compliance signals we monitor. Every CTM is tied to a specific agent by their National Producer Number (NPN) and rolls up to your agency's rate.
How it's calculated: Spark divides the number of founded CTMs over the past 12 months by your agency's total enrollments over the same period, then multiplies by 1,000. Only founded cases count — cases that were reviewed and confirmed as valid. Unfounded cases are not included.
One important note: Carriers track CTMs independently and apply their own thresholds, look-back periods, and enforcement actions. A carrier may take action against an agent or your agency based on their own data, which may differ from Spark's CAMP thresholds. Carrier actions are separate from CAMP and are outside of Spark's control.
2. Founded Non-CTM Case Rate per 1,000 Enrollments
What it is: The rate of founded non-CTM complaints across your agency, calculated as the number of founded non-CTM cases per 1,000 enrollments over a rolling 12-month window.
The threshold:
Low Risk: fewer than 10 founded non-CTM cases per 1,000 enrollments
Medium Risk: 10 or more founded non-CTM cases per 1,000 enrollments
Why it matters: Non-CTM complaints are allegations or grievances submitted by beneficiaries directly to carriers. They don't go through the CMS complaint portal, but carriers take them seriously and so does Spark. A pattern of non-CTM complaints signals the same types of conduct concerns as CTMs and can result in carrier watch list placements or corrective action — in addition to affecting your agency's CAMP tier.
How it's calculated: The same way as the CTM rate — founded non-CTM cases over the past 12 months divided by total enrollments, multiplied by 1,000. Again, only founded cases count.
How the Two Metrics Work Together
The worse metric sets your tier. If your CTM rate is below 2 but your non-CTM case rate is at or above 10, your agency is at Medium Risk. Both metrics must be below their respective thresholds for your agency to be at Low Risk.
Minimums apply: Rate-based metrics can only trigger a tier change once your agency has at least 20 total founded cases on record. This is designed to protect agencies with low case volume from being penalized by rates calculated on a very small number of cases.
Other Inputs That Affect Your Agency's Standing
While the two rate metrics above set your tier, Spark also monitors the following as part of your agency's overall compliance picture:
SEP Utilization
Accretion Rates
Rapid Disenrollment Rates
Call quality scores
Carrier compliance flags
Marketing compliance
Licensing and certification status
Case responsiveness
Terminated agent metrics
How to Track Your Agency's Performance
Your Account Manager can provide a summary of your agency's current metrics at any time. If you believe any data point is inaccurate, reach out to your Account Manager to request a review. We want to make sure your tier reflects your agency's actual performance.
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].