This article is a must-read if you’re an insurance agent working in Wisconsin.
The State of Wisconsin Office of the Commissioner of Insurance (OCI) has determined that the “NPN override” practice, where unappointed insurance intermediaries submit applications to insurers using the National Producer Number (NPN) of an appointed intermediary, is illegal in Wisconsin.
It’s illegal to do NPN overrides in Wisconsin.
This determination from the OCI results from the agency receiving several consumer complaints alleging fraudulent enrollment in Affordable Care Act plans by insurance intermediaries offered through the federal marketplace.
OCI found many complaints about intermediaries using the “National Producer Number (NPN) override” function on Enhanced Direct Enrollment (EDE) platforms to submit the application generating the complaint.
An intermediary designating themselves as the agent of record without doing the enrollment violates Wisconsin law prohibiting misrepresentations relating to insurance contracts.
OCI also ruled that this intermediary activity was “improper” under OCI’s “appointment and proper exchange of business” provisions and couldn’t be used to bypass the appointment requirements of Wisconsin statutes.
No intermediaries and no agencies can route agency sales through a single appointed intermediary with an insurance company.
Agility understands agents working in Wisconsin will have questions about this ruling from the Wisconsin OCI. We include the entire bulletin from the OCI about this for your reference here. Agents can also contact Chief Legal Counsel Lauren Van Buren at the OCI by emailing [email protected].
With the recent release of the proposed ACA CMS rules for 2025 and what North Carolina has already done on NPN overrides, it looks like the way NPN overrides will work in 2025 can change at any time. Agility will keep agents in the loop on everything happening and how they can adjust to any changes.
Don’t wait for change to happen—prepare for it now. Contact Agility at (866) 590-9771 or email [email protected] for a free strategy session that will prepare you for what changes can occur and how you can successfully navigate them to continued success as an insurance agent.
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