Overview
Under CAMP, every agent in your network is monitored individually — separate from your agency's overall tier. An agent's metrics determine whether they may be placed on Watchlist status or suspended from selling under Spark.
As an agency owner or principal, you are the first line of oversight for your agents. This article explains exactly how your agents are evaluated and what you can do to help them stay in good standing.
The Metrics That Matter for Agents
1. Total CTM Count
What it is: The total number of founded Complaints to Medicare associated with the agent over a rolling 12-month window.
Spark's thresholds:
Total CTM Count (12-month rolling) | Action |
3 or more | Agent placed on Watchlist |
6 or more | Agent subject to suspension |
Important: These are Spark's CAMP thresholds. Carriers set and enforce their own CTM thresholds independently, with their own look-back periods and criteria. A carrier may take action against an agent at a lower count or based on different criteria than Spark's. Carrier actions are outside of Spark's control and can occur at any time, separate from CAMP.
2. Founded Non-CTM Count
What it is: The total number of founded non-CTM complaints — allegations or grievances submitted by beneficiaries directly to carriers — associated with the agent over a rolling 12-month window.
Spark's thresholds:
Founded Non-CTM Count (12-month rolling) | Action |
7 or more | Agent placed on Watchlist |
10 or more | Agent subject to suspension |
3. Case Responsiveness
What it is: Whether the agent responds to open compliance cases within the required timeframe.
This is treated differently from CTM and non-CTM thresholds. When a compliance case is opened against an agent, the agent will receive a notice with a specific response deadline — typically 5 business days. This deadline will be clearly communicated in the notice.
If an agent does not respond by their deadline, they will be suspended immediately — outside of the normal monthly review cycle, and regardless of where their CTM or non-CTM counts stand. The suspension stays in effect until the case is resolved.
This is one of the most preventable suspension triggers. Please make sure your agents know to respond to all compliance communications promptly and to flag any questions to you or to Spark right away.
Supporting Context Metrics
In addition to the primary metrics above, Spark tracks the following on a 3-month rolling basis. These are not standalone suspension triggers, but they are reviewed as part of the full picture of an agent's performance — including in reinstatement decisions.
Accretion Rate — The percentage of applications submitted by the agent that convert to active enrollments within 3 months. A low accretion rate may signal that plans are being recommended that don't fit the beneficiary's needs, or that sales practices are creating enrollment issues. Most agents have a healthy accretion rate when they're doing thorough needs assessments and matching beneficiaries to appropriate plans.
RDE Rate (Rapid Disenrollment Rate) — The percentage of the agent's enrollments that are canceled within 3 months of the effective date. A high RDE rate is a significant concern — it often means beneficiaries were placed in plans they didn't fully understand or that didn't work for them. High RDE rates are a leading indicator of the conduct issues that generate CTMs.
If Spark identifies concerning trends in either of these metrics, Compliance or your Account Manager will reach out to discuss.
What Happens When an Agent Hits a Threshold
Watchlist:
Your agency will receive written notice from Spark Compliance identifying the agent and the metrics that triggered Watchlist status. Coaching the agent is your responsibility at this stage. Spark will support you, but the agency must take the lead. Use the Watchlist notice as your signal to intervene before the situation escalates to a suspension.
Suspension:
Your agency will receive written notice from Spark Compliance. The suspension becomes effective 3 business days after notice is issued. You are responsible for informing the agent of their suspension, explaining the reason, and communicating the reinstatement requirements they must complete before they can return to selling.
See Agent Suspension for the full reinstatement process.
Your Role as an Agency Owner
You don't have to wait for Spark to flag an issue. Here's how to stay ahead of your agents' metrics:
Ask for agent-level data. Spark compliance can provide a breakdown of CTMs and founded cases by agent, request them at [email protected]. If you don't already have this visibility, request it.
Act on trends early. An agent moving from 1 to 2 CTMs is worth a conversation. Don't wait for 3.
Use call quality feedback. Agents with low call quality scores are at elevated risk for complaints. IX call quality reviews give you concrete, actionable coaching material. See Call Quality Program for details.
Keep certifications current. Expired AHIP or carrier certifications create compliance gaps that compound other issues.
Create a culture of transparency. Agents should feel comfortable coming to you when something goes wrong on a call — before it becomes a complaint.
Questions?
Contact your Account Manager or 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].