Compliant Cross-Selling Strategies for AEP
Cross-selling can be a powerful way to increase revenue during the Annual Enrollment Period (AEP), but it must be done right. It’s a natural opportunity to offer additional products that can truly benefit your clients. But with strict CMS guidelines and evolving rules, insurance agents need to know how to navigate compliant cross-selling strategies without crossing any lines.
At Midwestern Marketing, we’ve helped insurance agents across the country grow their books while staying well within CMS rules. If you’re looking to boost your sales techniques without raising red flags, this guide to compliant cross-selling is for you.
What Is Compliant Cross-Selling?
Understanding CMS Guidelines
Cross-selling refers to bundling other complementary products, like dental plans or final expense insurance, while discussing a client’s Medicare coverage. Centers for Medicare & Medicaid Services (CMS) have strict rules about how and when you can do this. The goal? Protect consumers from high-pressure or misleading sales tactics. Cross-selling efforts aren’t just about adding products; they’re about improving the overall customer experience and meeting real customer needs.
What You Can and Can’t Do During AEP
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Allowed |
Not Allowed |
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Discussing other health-related products (e.g., dental, vision) if included on the Scope of Appointment (SOA) |
Bringing up unrelated products not listed on the Scope of Appointment (SOA) |
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Cross-selling during follow-up appointment scheduled for that purpose |
Discussing life insurance or annuities during a Medicare sales appointment unless CMS permits it |
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Reviewing hospital indemnity or final expense when SOA allows |
Promoting non-health-related products during the same appointment without prior consent |
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Collecting and saving signed SOAs before the appointment |
Relying on verbal permission to discuss other product lines |
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Educating clients on approved add-ons within the scope of their Medicare plan |
Mixing sales pitches into CMS-defined educational events |
By following these rules, you ensure a better customer journey and build stronger customer relationships over time.
When Can You Cross-Sell?
Scope of Appointment Requirements
Before you discuss anything outside of Medicare Advantage or Part D, make sure it’s listed on the Scope of Appointment. That’s your ticket to a compliant conversation. Always have the SOA signed and dated before the appointment, verbal permission alone won’t cut it.
Timing and Communication Rules
Keep your topics aligned with the SOA. If the client wants to talk about a dental plan during the appointment but didn’t check that box, you’ll need to schedule a follow-up. CMS rules also limit door-to-door marketing and cold-calling practices, so make sure your marketing strategy follows the book.
Proper timing and transparency in customer interaction leads to higher customer satisfaction and better customer retention.
Effective Cross-Selling Opportunities That Work
H3: Hospital Indemnity Plans
Many Medicare Advantage plans come with out-of-pocket costs. Hospital indemnity insurance helps cover those gaps. When clients understand how it complements their MA plan, they’re more likely to appreciate the value—and you stay compliant if it’s listed on the SOA.
Dental, Vision, and Hearing Coverage
Original Medicare doesn’t cover routine dental, vision, or hearing services. These plans are often a natural next step for clients looking for more complete coverage. Just be sure the client approved this category for discussion in advance.
Final Expense Insurance
Final expense insurance gives clients peace of mind and can be introduced during a compliant cross-selling appointment if the SOA includes life insurance. Keep your language focused on the benefit to the client, not on fear tactics.
There are great examples of cross-selling relevant products that add real value and increase customer lifetime value while remaining compliant.
Tips for Staying Compliant
Documentation Best Practices
Keep all signed SOAs on file for at least 10 years. Use digital tools or a CRM to track customer data, conversations, appointments, and what was discussed. Document everything, including what wasn’t talked about if the client declined certain coverage.
Avoiding Common Pitfalls
The biggest mistakes agents make? Bringing up non-approved product recommendations during a Medicare call or failing to properly time their follow-ups. Also, don’t mix educational events with sales pitches. Compliance isn’t just a requirement; it’s a way to serve your customer base with integrity.
When your sales strategy aligns with CMS rules, it increases your conversion rate and makes your sales teams more effective in the long run.
Training Your Team on Compliance
Annual CMS Training Requirements
Every agent must complete the annual Medicare compliance training. Make sure your entire team is certified and fully aware of the year’s updates. A strong understanding of the rules is the first line of defense.
Internal Review Checklists
Create checklists for appointments, enrollment, and follow-ups. This helps agents remember to collect SOAs, document properly, and stick to the allowed topics and cross-sales. Consistent processes lead to fewer errors and fewer headaches. Even loyal customers can lose trust if you don’t train your salesforce to prioritize compliance.
Why Compliance Matters for Your Reputation
Penalties and Fines
Non-compliance can lead to serious consequences: revoked contracts, hefty fines, and even being banned from selling Medicare products and complementary items. One wrong move can damage everything you’ve worked for.
Maintaining Trust with Clients
Your clients trust you to do what’s right for them. When you follow the rules, you build a reputation for professionalism and care. That kind of trust turns into long-term customer loyalty and referrals from both existing customers and new customers.
When you use the right cross-selling techniques, it doesn’t just increase sales, it helps build trust and add value to every interaction.
Do It Right, Do It Well
Compliant cross-selling isn’t just about checking boxes—it’s about putting your clients’ needs first while building a business that’s both successful and sustainable. When done right, cross-selling can enhance coverage, strengthen relationships, and increase your bottom line, all without risking your reputation.
At Midwestern Marketing, we believe the most successful agents are the ones who lead with integrity and stay informed. That’s why we’re here to help you navigate AEP with confidence, clarity, and compliance.
Need help navigating AEP and staying compliant while growing your sales?
Let’s connect. Contact Midwestern Marketing today and get the support you need to do AEP the right way.
Cross-selling occurs when an opportunity to sell a Medicare plan is also utilized to sell a non-health related product (such as life or home insurance or financial planning services). This activity is prohibited during individual appointments, marketing/sales events or when providing Medicare plan enrollment materials to consumers. Review the current Medicare Advantage Marketing Regulations and make sure you’re complying with Medicare’s rules regarding cross-selling.