CMS Updates 2025 Agent Compensation Rates, Submissions, & Training Requirements

The Centers for Medicare & Medicaid Services (CMS) recently released a memo detailing updates to Contract Year (CY) 2025 agent and broker compensation rates, submissions, and training and testing requirements. The policies, released on July 18, override the previous changes CMS enacted on June 28, 2024.

The compensation rates in effect are outlined below:

CMS also released requirements for compensation rate submissions for organizations. Under this rule, organizations must report to CMS whether they intend to use employed, captive, or independent agents or brokers in the upcoming plan year and what the specific rates (or ranges of rates) will be paid to agents or brokers. These functions, which were previously removed from the Health Plan Management System (HPMS) based on earlier rulings, were reinstated on July 19th.

The original deadline for these submissions was July 26th; however, due to uncertainty from pending litigation, CMS stated it would not pursue compliance actions against those missing the deadline, provided they make a good faith effort to submit the requirements to CMS and HPMS in a timely manner.

CMS also updated portions of the Agent/Brokers Training & Testing guidelines. The only change is removing language related to the provisions the court enjoined. View the updated training guidelines for CY 2025 here.

Read the full memo from CMS here.