mapdbot.ai

Answers

How can I generate referrals and work with churches, senior centers, or other community organizations while staying compliant?

Any referral compensation arrangement is capped and structured by CMS rules described below, though the specifics of how a particular church or senior center relationship should be set up contractually are not addressed in the CMS sources — that's a matter for your carrier/FMO agreement and, potentially, state law.

What the rule says

On referral payments, CMS regulation sets dollar caps:

“Payments may be made to individuals for the referral (including a recommendation, provision, or other means of referring beneficiaries), recommendation, provision, or other means of referring beneficiaries to an agent, broker or other entity for potential enrollment into a plan.”
42 CFR § 423.2274(f)
“The payment may not exceed $100 for a referral into an MA or MA-PD plan and $25 for a referral into a PDP plan.”
42 CFR § 422.2274(f) / § 423.2274(f)

If the community organization functions as a Third-Party Marketing Organization (TPMO) generating leads, additional disclosure duties apply. This is a list of conditions the TPMO must meet:

“Disclose to the beneficiary that his or her information will be provided to a licensed agent for future contact.”
42 CFR § 422.2274(g)(3)(i)
“Disclose to the beneficiary that he or she is being transferred to a licensed agent who can enroll him or her into a new plan.”
42 CFR § 422.2274(g)(3)(ii)

Separately, if you hold events at these venues, the event-type rules apply. For educational events (e.g., a talk at a senior center):

“Educational events must be advertised as such and be designed to generally inform beneficiaries about Medicare, including Medicare Advantage, Prescription Drug programs, or any other Medicare program.”
42 CFR § 422.2264(c)(1) / § 423.2264(c)(1)
“At educational events, MA organizations and agents/brokers may not market specific MA plans or benefits.”
42 CFR § 422.2264(c)(1)(i)

If it's a marketing/sales event instead, different rules apply, including a bar on requiring sign-in as a condition of attendance:

“Require sign-in sheets or require attendees to provide contact information as a prerequisite for attending an event.”
42 CFR § 422.2264(c)(2)(iii)(A)

The facts that would determine which rules govern your specific plan: whether the organization/individual is being paid for referrals (triggering the $100/$25 cap), whether it qualifies as a TPMO doing lead generation, and whether your activity there is an "educational event" or a "marketing/sales event."

Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.

This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.

Sources cited

Ask your own question